Identification of the Federal Program: Student Financial Assistance Cluster (?SFA Cluster?) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student?s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 3 students selected for transfer monitoring testing, the University was unable to provide support that the required transfer monitoring procedures were performed. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: Exceptions were noted for 3 of 15 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University?s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeat finding, the University?s corrective action plan is being implemented immediately?Spring 2023. An internal review will be performed using Spring 2023 data with the assistance of the Director of Financial Aid, Director of Transfer Students and a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb).
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Status Change: Institutions are required to update students? statuses on the NSLDS website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-003. Recommendation: We recommend that the University enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination with the Information Technology Division will develop a ?flag based? process to capture and review all enrollment status changes on a monthly basis. This new reporting process will enhance the Registrar?s ability to review and accurately submit timely notifications to the National Student Loan Data System (?NSLDS?). These monthly reviews will be recorded and memorialized for the record.
Identification of the Federal Program: Student Financial Assistance Cluster (?SFA Cluster?) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student?s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 3 students selected for transfer monitoring testing, the University was unable to provide support that the required transfer monitoring procedures were performed. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: Exceptions were noted for 3 of 15 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University?s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeat finding, the University?s corrective action plan is being implemented immediately?Spring 2023. An internal review will be performed using Spring 2023 data with the assistance of the Director of Financial Aid, Director of Transfer Students and a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb).
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Status Change: Institutions are required to update students? statuses on the NSLDS website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-003. Recommendation: We recommend that the University enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination with the Information Technology Division will develop a ?flag based? process to capture and review all enrollment status changes on a monthly basis. This new reporting process will enhance the Registrar?s ability to review and accurately submit timely notifications to the National Student Loan Data System (?NSLDS?). These monthly reviews will be recorded and memorialized for the record.
Identification of the Federal Program: Student Financial Assistance Cluster (?SFA Cluster?) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student?s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 3 students selected for transfer monitoring testing, the University was unable to provide support that the required transfer monitoring procedures were performed. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: Exceptions were noted for 3 of 15 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University?s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeat finding, the University?s corrective action plan is being implemented immediately?Spring 2023. An internal review will be performed using Spring 2023 data with the assistance of the Director of Financial Aid, Director of Transfer Students and a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb).
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Status Change: Institutions are required to update students? statuses on the NSLDS website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-003. Recommendation: We recommend that the University enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination with the Information Technology Division will develop a ?flag based? process to capture and review all enrollment status changes on a monthly basis. This new reporting process will enhance the Registrar?s ability to review and accurately submit timely notifications to the National Student Loan Data System (?NSLDS?). These monthly reviews will be recorded and memorialized for the record.
Identification of the Federal Program: Student Financial Assistance Cluster (?SFA Cluster?) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student?s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 3 students selected for transfer monitoring testing, the University was unable to provide support that the required transfer monitoring procedures were performed. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: Exceptions were noted for 3 of 15 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University?s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeat finding, the University?s corrective action plan is being implemented immediately?Spring 2023. An internal review will be performed using Spring 2023 data with the assistance of the Director of Financial Aid, Director of Transfer Students and a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb).
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Status Change: Institutions are required to update students? statuses on the NSLDS website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-003. Recommendation: We recommend that the University enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination with the Information Technology Division will develop a ?flag based? process to capture and review all enrollment status changes on a monthly basis. This new reporting process will enhance the Registrar?s ability to review and accurately submit timely notifications to the National Student Loan Data System (?NSLDS?). These monthly reviews will be recorded and memorialized for the record.
Identification of the Federal Program: Federal Direct Loan Program (CFDA #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students: For students that received disbursements of Direct Loans or Federal Perkins Loans, institutions must notify the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution. For first time borrowers, the University cannot distribute funds to students before the passage of 30 days after the student?s first day of classes. Condition: The University notified 2 students/parents of their loan disbursements more than 30 days before crediting the student?s account. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students. Questioned Costs: None. Context: Exceptions were noted for 2 of 25 students selected for notification testing. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhances its internal controls over the compliance requirements of Special Tests and Provisions ? Disbursements To or On Behalf of Students. Views of Responsible Officials: The Financial Aid division has revised its compliance process to ensure the effective administrative and internal control oversight of the notification of the Direct Loan disbursements. As a part of this revised compliance process, students receiving financial aid while attending one or more other institutions will be ?singled out? for a detail review in accordance with the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. The Director of Financial Aid will perform periodic reviews to ensure the new process is being effectively executed in a timely and accurate manner. An internal review will be performed Spring 2023 with the Director of Financial Aid, Data Coordinator and neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb).
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (Assistance Listing #84.425E), HEERF Institutional Portion (Assistance Listing #84.425F) and HEERF Historically Black Colleges and Universities (?HBCUs?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? There are three components to reporting for the Higher Education Emergency Relief Fund (?HEERF?): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report. Condition: The University did not submit certain quarterly reports and submitted its annual report subsequent to the required deadline for the year ended June 30, 2022. Certain information submitted to the funding agency within financial reports was not accurate and not appropriately reconciled to the University?s records. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with the quarterly reporting and annual reporting requirements of the HEERF program. Questioned Costs: None. Context: For 2 of 3 quarterly reports selected for testing and 1 of 1 annual report selected for testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-004. Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that they are posted within the required time frames. Views of Responsible Officials: To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University?s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be internally by the Assistant Provost for sponsored program, who will function as a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record on a monthly basis). The University Controller in coordination with the Financial Aid Director will prepare required reports and submit to the CFO for review. Once the CFO has reviewed, and approved, a service request will be submitted to the University IT to post the information to the website. The CIO has identified a technician with the necessary skill set to update the website until a permanent web-master can be identified (currently being conducted through contractual services). Once the website has been updated the service ticket will be updated and closed.
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (?Student Aid Portion?) (Assistance Listing #84.425E) and HEERF Historically Black Colleges and Universities (?HBCUs Aid Portion?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management: In addition to these basic cash management principles, for Coronavirus Response and Relief Supplemental Appropriations Act (?CRRSAA?) HEERF II and America Rescue Plan (?ARP?) HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (AL #84.425E) should be disbursed within 15 calendar days of the drawdown from the U.S. Department U.S. Department of Education?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the draw down from G5. Condition: Student Aid Portion: For 1 period of time in excess of 15 calendar days during the year ended June 30, 2022, the University had cumulative drawn down funds that exceeded the cumulative disbursements. HBCUs Aid Portion: For 1 period of time in excess of 3 calendar days during the year ended June 30, 2022, the University had cumulative drawn down funds that exceeded the cumulative disbursements. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the cash management requirements of the Education Stabilization Fund program. Questioned Costs: None. Context: Refer to the Condition section of this finding for the context. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: We recommend that the University enhances its internal controls to ensure compliance with the cash management requirements of the Education Stabilization Fund program. Views of Responsible Officials: To enhance the internal controls to ensure compliance with the cash management requirements of the Education Stabilization Fund program, the University will immediately implement a draw down/disbursement reconciliation plan. Our compliance committee will review each draw down, to ensure that disbursements are recorded in accordance with the Student Aid Portion and Institutional Aid Portion policies. The review of this process will be recorded and memorialized for the record.
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (Assistance Listing #84.425E), HEERF Institutional Portion (Assistance Listing #84.425F) and HEERF Historically Black Colleges and Universities (?HBCUs?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? There are three components to reporting for the Higher Education Emergency Relief Fund (?HEERF?): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report. Condition: The University did not submit certain quarterly reports and submitted its annual report subsequent to the required deadline for the year ended June 30, 2022. Certain information submitted to the funding agency within financial reports was not accurate and not appropriately reconciled to the University?s records. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with the quarterly reporting and annual reporting requirements of the HEERF program. Questioned Costs: None. Context: For 2 of 3 quarterly reports selected for testing and 1 of 1 annual report selected for testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-004. Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that they are posted within the required time frames. Views of Responsible Officials: To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University?s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be internally by the Assistant Provost for sponsored program, who will function as a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record on a monthly basis). The University Controller in coordination with the Financial Aid Director will prepare required reports and submit to the CFO for review. Once the CFO has reviewed, and approved, a service request will be submitted to the University IT to post the information to the website. The CIO has identified a technician with the necessary skill set to update the website until a permanent web-master can be identified (currently being conducted through contractual services). Once the website has been updated the service ticket will be updated and closed.
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (Assistance Listing #84.425E), HEERF Institutional Portion (Assistance Listing #84.425F) and HEERF Historically Black Colleges and Universities (?HBCUs?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? There are three components to reporting for the Higher Education Emergency Relief Fund (?HEERF?): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report. Condition: The University did not submit certain quarterly reports and submitted its annual report subsequent to the required deadline for the year ended June 30, 2022. Certain information submitted to the funding agency within financial reports was not accurate and not appropriately reconciled to the University?s records. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with the quarterly reporting and annual reporting requirements of the HEERF program. Questioned Costs: None. Context: For 2 of 3 quarterly reports selected for testing and 1 of 1 annual report selected for testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-004. Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that they are posted within the required time frames. Views of Responsible Officials: To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University?s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be internally by the Assistant Provost for sponsored program, who will function as a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record on a monthly basis). The University Controller in coordination with the Financial Aid Director will prepare required reports and submit to the CFO for review. Once the CFO has reviewed, and approved, a service request will be submitted to the University IT to post the information to the website. The CIO has identified a technician with the necessary skill set to update the website until a permanent web-master can be identified (currently being conducted through contractual services). Once the website has been updated the service ticket will be updated and closed.
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (?Student Aid Portion?) (Assistance Listing #84.425E) and HEERF Historically Black Colleges and Universities (?HBCUs Aid Portion?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management: In addition to these basic cash management principles, for Coronavirus Response and Relief Supplemental Appropriations Act (?CRRSAA?) HEERF II and America Rescue Plan (?ARP?) HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (AL #84.425E) should be disbursed within 15 calendar days of the drawdown from the U.S. Department U.S. Department of Education?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the draw down from G5. Condition: Student Aid Portion: For 1 period of time in excess of 15 calendar days during the year ended June 30, 2022, the University had cumulative drawn down funds that exceeded the cumulative disbursements. HBCUs Aid Portion: For 1 period of time in excess of 3 calendar days during the year ended June 30, 2022, the University had cumulative drawn down funds that exceeded the cumulative disbursements. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the cash management requirements of the Education Stabilization Fund program. Questioned Costs: None. Context: Refer to the Condition section of this finding for the context. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: We recommend that the University enhances its internal controls to ensure compliance with the cash management requirements of the Education Stabilization Fund program. Views of Responsible Officials: To enhance the internal controls to ensure compliance with the cash management requirements of the Education Stabilization Fund program, the University will immediately implement a draw down/disbursement reconciliation plan. Our compliance committee will review each draw down, to ensure that disbursements are recorded in accordance with the Student Aid Portion and Institutional Aid Portion policies. The review of this process will be recorded and memorialized for the record.
Identification of the Federal Program: Federal Perkins Loan Program (Assistance Listing #: 84.038) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Perkins Loan Recordkeeping and Record Retention: Institutions are required to keep original paper promissory notes or original paper master promissory notes and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. After the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full and retain a copy for the prescribed period. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third party servicer is in compliance with the requirements for the functions the third party servicer is performing for the school. Condition: For 6 students selected for testing, the University was unable to provide evidence that the student?s Perkins Loan repayment schedule was retained as required. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the Perkins Loan Recordkeeping and Record Retention requirements. Questioned Costs: None. Context: For 6 of 25 students selected for Perkins Loan Recordkeeping and Record retention testing, an exception was noted. Identification as a Repeat Finding: This is a repeat or prior year finding 2021-007. Recommendation: We recommend that the University enhances its internal controls to ensure compliance with the special reporting requirements. Views of Responsible Officials: In our effort to enhance our ability to access older Perkins Loan records, we will engage our information technology consultants to research our information collection system. Currently our ability to access older Perkins Loan records is restricted due to system constraints. The findings from this engagement will be recorded and memorialized for the record.
Identification of the Federal Program: Student Financial Assistance Cluster (?SFA Cluster?) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student?s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 3 students selected for transfer monitoring testing, the University was unable to provide support that the required transfer monitoring procedures were performed. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: Exceptions were noted for 3 of 15 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University?s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeat finding, the University?s corrective action plan is being implemented immediately?Spring 2023. An internal review will be performed using Spring 2023 data with the assistance of the Director of Financial Aid, Director of Transfer Students and a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb).
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Status Change: Institutions are required to update students? statuses on the NSLDS website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-003. Recommendation: We recommend that the University enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination with the Information Technology Division will develop a ?flag based? process to capture and review all enrollment status changes on a monthly basis. This new reporting process will enhance the Registrar?s ability to review and accurately submit timely notifications to the National Student Loan Data System (?NSLDS?). These monthly reviews will be recorded and memorialized for the record.
Identification of the Federal Program: Student Financial Assistance Cluster (?SFA Cluster?) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student?s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 3 students selected for transfer monitoring testing, the University was unable to provide support that the required transfer monitoring procedures were performed. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: Exceptions were noted for 3 of 15 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University?s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeat finding, the University?s corrective action plan is being implemented immediately?Spring 2023. An internal review will be performed using Spring 2023 data with the assistance of the Director of Financial Aid, Director of Transfer Students and a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb).
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Status Change: Institutions are required to update students? statuses on the NSLDS website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-003. Recommendation: We recommend that the University enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination with the Information Technology Division will develop a ?flag based? process to capture and review all enrollment status changes on a monthly basis. This new reporting process will enhance the Registrar?s ability to review and accurately submit timely notifications to the National Student Loan Data System (?NSLDS?). These monthly reviews will be recorded and memorialized for the record.
Identification of the Federal Program: Student Financial Assistance Cluster (?SFA Cluster?) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student?s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 3 students selected for transfer monitoring testing, the University was unable to provide support that the required transfer monitoring procedures were performed. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: Exceptions were noted for 3 of 15 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University?s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeat finding, the University?s corrective action plan is being implemented immediately?Spring 2023. An internal review will be performed using Spring 2023 data with the assistance of the Director of Financial Aid, Director of Transfer Students and a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb).
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Status Change: Institutions are required to update students? statuses on the NSLDS website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-003. Recommendation: We recommend that the University enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination with the Information Technology Division will develop a ?flag based? process to capture and review all enrollment status changes on a monthly basis. This new reporting process will enhance the Registrar?s ability to review and accurately submit timely notifications to the National Student Loan Data System (?NSLDS?). These monthly reviews will be recorded and memorialized for the record.
Identification of the Federal Program: Student Financial Assistance Cluster (?SFA Cluster?) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student?s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 3 students selected for transfer monitoring testing, the University was unable to provide support that the required transfer monitoring procedures were performed. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: Exceptions were noted for 3 of 15 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University?s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeat finding, the University?s corrective action plan is being implemented immediately?Spring 2023. An internal review will be performed using Spring 2023 data with the assistance of the Director of Financial Aid, Director of Transfer Students and a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb).
Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Status Change: Institutions are required to update students? statuses on the NSLDS website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-003. Recommendation: We recommend that the University enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination with the Information Technology Division will develop a ?flag based? process to capture and review all enrollment status changes on a monthly basis. This new reporting process will enhance the Registrar?s ability to review and accurately submit timely notifications to the National Student Loan Data System (?NSLDS?). These monthly reviews will be recorded and memorialized for the record.
Identification of the Federal Program: Federal Direct Loan Program (CFDA #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students: For students that received disbursements of Direct Loans or Federal Perkins Loans, institutions must notify the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution. For first time borrowers, the University cannot distribute funds to students before the passage of 30 days after the student?s first day of classes. Condition: The University notified 2 students/parents of their loan disbursements more than 30 days before crediting the student?s account. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students. Questioned Costs: None. Context: Exceptions were noted for 2 of 25 students selected for notification testing. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhances its internal controls over the compliance requirements of Special Tests and Provisions ? Disbursements To or On Behalf of Students. Views of Responsible Officials: The Financial Aid division has revised its compliance process to ensure the effective administrative and internal control oversight of the notification of the Direct Loan disbursements. As a part of this revised compliance process, students receiving financial aid while attending one or more other institutions will be ?singled out? for a detail review in accordance with the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. The Director of Financial Aid will perform periodic reviews to ensure the new process is being effectively executed in a timely and accurate manner. An internal review will be performed Spring 2023 with the Director of Financial Aid, Data Coordinator and neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb).
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (Assistance Listing #84.425E), HEERF Institutional Portion (Assistance Listing #84.425F) and HEERF Historically Black Colleges and Universities (?HBCUs?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? There are three components to reporting for the Higher Education Emergency Relief Fund (?HEERF?): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report. Condition: The University did not submit certain quarterly reports and submitted its annual report subsequent to the required deadline for the year ended June 30, 2022. Certain information submitted to the funding agency within financial reports was not accurate and not appropriately reconciled to the University?s records. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with the quarterly reporting and annual reporting requirements of the HEERF program. Questioned Costs: None. Context: For 2 of 3 quarterly reports selected for testing and 1 of 1 annual report selected for testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-004. Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that they are posted within the required time frames. Views of Responsible Officials: To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University?s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be internally by the Assistant Provost for sponsored program, who will function as a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record on a monthly basis). The University Controller in coordination with the Financial Aid Director will prepare required reports and submit to the CFO for review. Once the CFO has reviewed, and approved, a service request will be submitted to the University IT to post the information to the website. The CIO has identified a technician with the necessary skill set to update the website until a permanent web-master can be identified (currently being conducted through contractual services). Once the website has been updated the service ticket will be updated and closed.
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (?Student Aid Portion?) (Assistance Listing #84.425E) and HEERF Historically Black Colleges and Universities (?HBCUs Aid Portion?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management: In addition to these basic cash management principles, for Coronavirus Response and Relief Supplemental Appropriations Act (?CRRSAA?) HEERF II and America Rescue Plan (?ARP?) HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (AL #84.425E) should be disbursed within 15 calendar days of the drawdown from the U.S. Department U.S. Department of Education?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the draw down from G5. Condition: Student Aid Portion: For 1 period of time in excess of 15 calendar days during the year ended June 30, 2022, the University had cumulative drawn down funds that exceeded the cumulative disbursements. HBCUs Aid Portion: For 1 period of time in excess of 3 calendar days during the year ended June 30, 2022, the University had cumulative drawn down funds that exceeded the cumulative disbursements. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the cash management requirements of the Education Stabilization Fund program. Questioned Costs: None. Context: Refer to the Condition section of this finding for the context. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: We recommend that the University enhances its internal controls to ensure compliance with the cash management requirements of the Education Stabilization Fund program. Views of Responsible Officials: To enhance the internal controls to ensure compliance with the cash management requirements of the Education Stabilization Fund program, the University will immediately implement a draw down/disbursement reconciliation plan. Our compliance committee will review each draw down, to ensure that disbursements are recorded in accordance with the Student Aid Portion and Institutional Aid Portion policies. The review of this process will be recorded and memorialized for the record.
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (Assistance Listing #84.425E), HEERF Institutional Portion (Assistance Listing #84.425F) and HEERF Historically Black Colleges and Universities (?HBCUs?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? There are three components to reporting for the Higher Education Emergency Relief Fund (?HEERF?): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report. Condition: The University did not submit certain quarterly reports and submitted its annual report subsequent to the required deadline for the year ended June 30, 2022. Certain information submitted to the funding agency within financial reports was not accurate and not appropriately reconciled to the University?s records. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with the quarterly reporting and annual reporting requirements of the HEERF program. Questioned Costs: None. Context: For 2 of 3 quarterly reports selected for testing and 1 of 1 annual report selected for testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-004. Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that they are posted within the required time frames. Views of Responsible Officials: To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University?s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be internally by the Assistant Provost for sponsored program, who will function as a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record on a monthly basis). The University Controller in coordination with the Financial Aid Director will prepare required reports and submit to the CFO for review. Once the CFO has reviewed, and approved, a service request will be submitted to the University IT to post the information to the website. The CIO has identified a technician with the necessary skill set to update the website until a permanent web-master can be identified (currently being conducted through contractual services). Once the website has been updated the service ticket will be updated and closed.
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (Assistance Listing #84.425E), HEERF Institutional Portion (Assistance Listing #84.425F) and HEERF Historically Black Colleges and Universities (?HBCUs?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? There are three components to reporting for the Higher Education Emergency Relief Fund (?HEERF?): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report. Condition: The University did not submit certain quarterly reports and submitted its annual report subsequent to the required deadline for the year ended June 30, 2022. Certain information submitted to the funding agency within financial reports was not accurate and not appropriately reconciled to the University?s records. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with the quarterly reporting and annual reporting requirements of the HEERF program. Questioned Costs: None. Context: For 2 of 3 quarterly reports selected for testing and 1 of 1 annual report selected for testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-004. Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that they are posted within the required time frames. Views of Responsible Officials: To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University?s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be internally by the Assistant Provost for sponsored program, who will function as a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record on a monthly basis). The University Controller in coordination with the Financial Aid Director will prepare required reports and submit to the CFO for review. Once the CFO has reviewed, and approved, a service request will be submitted to the University IT to post the information to the website. The CIO has identified a technician with the necessary skill set to update the website until a permanent web-master can be identified (currently being conducted through contractual services). Once the website has been updated the service ticket will be updated and closed.
Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (?Student Aid Portion?) (Assistance Listing #84.425E) and HEERF Historically Black Colleges and Universities (?HBCUs Aid Portion?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management: In addition to these basic cash management principles, for Coronavirus Response and Relief Supplemental Appropriations Act (?CRRSAA?) HEERF II and America Rescue Plan (?ARP?) HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (AL #84.425E) should be disbursed within 15 calendar days of the drawdown from the U.S. Department U.S. Department of Education?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the draw down from G5. Condition: Student Aid Portion: For 1 period of time in excess of 15 calendar days during the year ended June 30, 2022, the University had cumulative drawn down funds that exceeded the cumulative disbursements. HBCUs Aid Portion: For 1 period of time in excess of 3 calendar days during the year ended June 30, 2022, the University had cumulative drawn down funds that exceeded the cumulative disbursements. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the cash management requirements of the Education Stabilization Fund program. Questioned Costs: None. Context: Refer to the Condition section of this finding for the context. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: We recommend that the University enhances its internal controls to ensure compliance with the cash management requirements of the Education Stabilization Fund program. Views of Responsible Officials: To enhance the internal controls to ensure compliance with the cash management requirements of the Education Stabilization Fund program, the University will immediately implement a draw down/disbursement reconciliation plan. Our compliance committee will review each draw down, to ensure that disbursements are recorded in accordance with the Student Aid Portion and Institutional Aid Portion policies. The review of this process will be recorded and memorialized for the record.
Identification of the Federal Program: Federal Perkins Loan Program (Assistance Listing #: 84.038) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Perkins Loan Recordkeeping and Record Retention: Institutions are required to keep original paper promissory notes or original paper master promissory notes and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. After the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full and retain a copy for the prescribed period. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third party servicer is in compliance with the requirements for the functions the third party servicer is performing for the school. Condition: For 6 students selected for testing, the University was unable to provide evidence that the student?s Perkins Loan repayment schedule was retained as required. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the Perkins Loan Recordkeeping and Record Retention requirements. Questioned Costs: None. Context: For 6 of 25 students selected for Perkins Loan Recordkeeping and Record retention testing, an exception was noted. Identification as a Repeat Finding: This is a repeat or prior year finding 2021-007. Recommendation: We recommend that the University enhances its internal controls to ensure compliance with the special reporting requirements. Views of Responsible Officials: In our effort to enhance our ability to access older Perkins Loan records, we will engage our information technology consultants to research our information collection system. Currently our ability to access older Perkins Loan records is restricted due to system constraints. The findings from this engagement will be recorded and memorialized for the record.