2022-001 Enrollment Reporting U.S. Department of Education Program (ED) Student Financial Assistance Programs Cluster Federal Direct Student Loans (ALN 84.268) Federal Perkins Loan Program (ALN 84.038) Federal Award Year: 2021?2022 Condition: Three student?s enrollments changes were not reported to the National Student Loan Data System (NSLDS) within the 60 day timeframe for the School?s reporting on the roster file submissions. Criteria: Per 34 CFR 685.309, Schools are required to accurately report enrollment information under the Direct Loan program via the NSLDS. Enrollment status changes for students should be reported to NSLDS within 30 days, or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the effective change in status or date of determination if the date of determination was determined after the withdrawal date. At a minimum, schools are required to certify enrollment every 60 days. Schools are also responsible for the accurate and timely reporting of high risk program-level record elements, which includes program type, length, and begin date; program enrollment status; and program enrollment effective date. Additionally, schools are required to accurately report enrollment information under the Direct Loan program to the NSLDS site. Cause: Management did not have effective internal controls in place to ensure that compliance with enrollment reporting requirements were followed. For one student?s status change, the National Student Clearinghouse did not submit the enrollment roster to NSLDS in a timely mater. For two students who graduated, the School did not report the students as withdrawn or graduated immediately after the end of the semester and within the required timeframe due to a delay in determining graduation requirements had been satisfied. The School ultimately reported the graduation status to the clearinghouse, but it was not early enough for the clearinghouse to report them on an enrollment roster to NSLDS to be in compliance with the 60 day reporting requirement. Effect: Inaccurate, late reporting may have an effect on timing of conversion to repayment status and/or the amount of repayment for students subject to an interest subsidy. In addition, inaccurate reporting could also cause an over-awarding issue if the student transfers to another school and award determination staff at the subsequent school are unable to accurately determine status and eligibility of the student. Prevalence: Three of the 61 status changes tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should review the controls and procedures in place to verify that accurate, timely and complete data is being submitted to NSLDS. This should include separation of preparation, review and completion, as well as methods to identify an accurate and complete reporting population. View of responsible officials of the auditee: Management agrees with this finding.
2022-002 HEERF Activities Allowed or Unallowed U.S. Department of Education Program Education Stabilization Fund (ESF) Subprograms Section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) Federal Award Year: 2021?2022 Condition: While testing activities allowed or unallowed in the audit of the 2020-2021 award year, we noted that there was a lack of a written plan to provide objective criteria for the distribution of funds until April 2022. Criteria: Per 2 CFR part 200 appendix XI, the School was required to have a documented plan to distribute funds to students. Per 2 CFR part 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report...as reported to the Federal awarding agency." Cause: Individuals involved in preparing the student award distribution plan were unaware of the requirement that the plan be documented and that the plan be retained by the School. Effect: Effective internal control over activities allowed or unallowed was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Applies to the entire HEERF program. Questioned costs: None. Repeat finding?: Yes Recommendation: Management should establish and maintain controls over activities allowed or unallowed. View of responsible officials of the auditee: Management agrees with this finding.
2022-003 HEERF Reporting U.S. Department of Education Program Education Stabilization Fund (ESF) subprograms section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) Federal Award Year: 2021?2022 Condition: While testing reporting, we noted that there were not controls or approvals over the reporting requirement for the HEERF program. Criteria: Per 2 CFR part 200.303, ?the non-Federal entity must: a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Effective internal controls should include procedures in place to ensure the proper reviews and approvals are performed over required reporting. Cause: Management did not have effective internal controls in place to ensure that reviews and approvals were performed over the reports due to the newness of the program. In addition, management placed more focus on addressing student needs instead of implementing controls over reporting. Effect: Effective internal control over reporting was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Two out of two reports tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should establish and maintain controls over reporting. View of responsible officials of the auditee: Management agrees with this finding.
2022-002 HEERF Activities Allowed or Unallowed U.S. Department of Education Program Education Stabilization Fund (ESF) Subprograms Section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) Federal Award Year: 2021?2022 Condition: While testing activities allowed or unallowed in the audit of the 2020-2021 award year, we noted that there was a lack of a written plan to provide objective criteria for the distribution of funds until April 2022. Criteria: Per 2 CFR part 200 appendix XI, the School was required to have a documented plan to distribute funds to students. Per 2 CFR part 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report...as reported to the Federal awarding agency." Cause: Individuals involved in preparing the student award distribution plan were unaware of the requirement that the plan be documented and that the plan be retained by the School. Effect: Effective internal control over activities allowed or unallowed was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Applies to the entire HEERF program. Questioned costs: None. Repeat finding?: Yes Recommendation: Management should establish and maintain controls over activities allowed or unallowed. View of responsible officials of the auditee: Management agrees with this finding.
2022-003 HEERF Reporting U.S. Department of Education Program Education Stabilization Fund (ESF) subprograms section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) Federal Award Year: 2021?2022 Condition: While testing reporting, we noted that there were not controls or approvals over the reporting requirement for the HEERF program. Criteria: Per 2 CFR part 200.303, ?the non-Federal entity must: a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Effective internal controls should include procedures in place to ensure the proper reviews and approvals are performed over required reporting. Cause: Management did not have effective internal controls in place to ensure that reviews and approvals were performed over the reports due to the newness of the program. In addition, management placed more focus on addressing student needs instead of implementing controls over reporting. Effect: Effective internal control over reporting was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Two out of two reports tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should establish and maintain controls over reporting. View of responsible officials of the auditee: Management agrees with this finding.
2022-001 Enrollment Reporting U.S. Department of Education Program (ED) Student Financial Assistance Programs Cluster Federal Direct Student Loans (ALN 84.268) Federal Perkins Loan Program (ALN 84.038) Federal Award Year: 2021?2022 Condition: Three student?s enrollments changes were not reported to the National Student Loan Data System (NSLDS) within the 60 day timeframe for the School?s reporting on the roster file submissions. Criteria: Per 34 CFR 685.309, Schools are required to accurately report enrollment information under the Direct Loan program via the NSLDS. Enrollment status changes for students should be reported to NSLDS within 30 days, or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the effective change in status or date of determination if the date of determination was determined after the withdrawal date. At a minimum, schools are required to certify enrollment every 60 days. Schools are also responsible for the accurate and timely reporting of high risk program-level record elements, which includes program type, length, and begin date; program enrollment status; and program enrollment effective date. Additionally, schools are required to accurately report enrollment information under the Direct Loan program to the NSLDS site. Cause: Management did not have effective internal controls in place to ensure that compliance with enrollment reporting requirements were followed. For one student?s status change, the National Student Clearinghouse did not submit the enrollment roster to NSLDS in a timely mater. For two students who graduated, the School did not report the students as withdrawn or graduated immediately after the end of the semester and within the required timeframe due to a delay in determining graduation requirements had been satisfied. The School ultimately reported the graduation status to the clearinghouse, but it was not early enough for the clearinghouse to report them on an enrollment roster to NSLDS to be in compliance with the 60 day reporting requirement. Effect: Inaccurate, late reporting may have an effect on timing of conversion to repayment status and/or the amount of repayment for students subject to an interest subsidy. In addition, inaccurate reporting could also cause an over-awarding issue if the student transfers to another school and award determination staff at the subsequent school are unable to accurately determine status and eligibility of the student. Prevalence: Three of the 61 status changes tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should review the controls and procedures in place to verify that accurate, timely and complete data is being submitted to NSLDS. This should include separation of preparation, review and completion, as well as methods to identify an accurate and complete reporting population. View of responsible officials of the auditee: Management agrees with this finding.
2022-001 Enrollment Reporting U.S. Department of Education Program (ED) Student Financial Assistance Programs Cluster Federal Direct Student Loans (ALN 84.268) Federal Perkins Loan Program (ALN 84.038) Federal Award Year: 2021?2022 Condition: Three student?s enrollments changes were not reported to the National Student Loan Data System (NSLDS) within the 60 day timeframe for the School?s reporting on the roster file submissions. Criteria: Per 34 CFR 685.309, Schools are required to accurately report enrollment information under the Direct Loan program via the NSLDS. Enrollment status changes for students should be reported to NSLDS within 30 days, or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the effective change in status or date of determination if the date of determination was determined after the withdrawal date. At a minimum, schools are required to certify enrollment every 60 days. Schools are also responsible for the accurate and timely reporting of high risk program-level record elements, which includes program type, length, and begin date; program enrollment status; and program enrollment effective date. Additionally, schools are required to accurately report enrollment information under the Direct Loan program to the NSLDS site. Cause: Management did not have effective internal controls in place to ensure that compliance with enrollment reporting requirements were followed. For one student?s status change, the National Student Clearinghouse did not submit the enrollment roster to NSLDS in a timely mater. For two students who graduated, the School did not report the students as withdrawn or graduated immediately after the end of the semester and within the required timeframe due to a delay in determining graduation requirements had been satisfied. The School ultimately reported the graduation status to the clearinghouse, but it was not early enough for the clearinghouse to report them on an enrollment roster to NSLDS to be in compliance with the 60 day reporting requirement. Effect: Inaccurate, late reporting may have an effect on timing of conversion to repayment status and/or the amount of repayment for students subject to an interest subsidy. In addition, inaccurate reporting could also cause an over-awarding issue if the student transfers to another school and award determination staff at the subsequent school are unable to accurately determine status and eligibility of the student. Prevalence: Three of the 61 status changes tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should review the controls and procedures in place to verify that accurate, timely and complete data is being submitted to NSLDS. This should include separation of preparation, review and completion, as well as methods to identify an accurate and complete reporting population. View of responsible officials of the auditee: Management agrees with this finding.
2022-002 HEERF Activities Allowed or Unallowed U.S. Department of Education Program Education Stabilization Fund (ESF) Subprograms Section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) Federal Award Year: 2021?2022 Condition: While testing activities allowed or unallowed in the audit of the 2020-2021 award year, we noted that there was a lack of a written plan to provide objective criteria for the distribution of funds until April 2022. Criteria: Per 2 CFR part 200 appendix XI, the School was required to have a documented plan to distribute funds to students. Per 2 CFR part 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report...as reported to the Federal awarding agency." Cause: Individuals involved in preparing the student award distribution plan were unaware of the requirement that the plan be documented and that the plan be retained by the School. Effect: Effective internal control over activities allowed or unallowed was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Applies to the entire HEERF program. Questioned costs: None. Repeat finding?: Yes Recommendation: Management should establish and maintain controls over activities allowed or unallowed. View of responsible officials of the auditee: Management agrees with this finding.
2022-003 HEERF Reporting U.S. Department of Education Program Education Stabilization Fund (ESF) subprograms section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) Federal Award Year: 2021?2022 Condition: While testing reporting, we noted that there were not controls or approvals over the reporting requirement for the HEERF program. Criteria: Per 2 CFR part 200.303, ?the non-Federal entity must: a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Effective internal controls should include procedures in place to ensure the proper reviews and approvals are performed over required reporting. Cause: Management did not have effective internal controls in place to ensure that reviews and approvals were performed over the reports due to the newness of the program. In addition, management placed more focus on addressing student needs instead of implementing controls over reporting. Effect: Effective internal control over reporting was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Two out of two reports tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should establish and maintain controls over reporting. View of responsible officials of the auditee: Management agrees with this finding.
2022-002 HEERF Activities Allowed or Unallowed U.S. Department of Education Program Education Stabilization Fund (ESF) Subprograms Section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) Federal Award Year: 2021?2022 Condition: While testing activities allowed or unallowed in the audit of the 2020-2021 award year, we noted that there was a lack of a written plan to provide objective criteria for the distribution of funds until April 2022. Criteria: Per 2 CFR part 200 appendix XI, the School was required to have a documented plan to distribute funds to students. Per 2 CFR part 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report...as reported to the Federal awarding agency." Cause: Individuals involved in preparing the student award distribution plan were unaware of the requirement that the plan be documented and that the plan be retained by the School. Effect: Effective internal control over activities allowed or unallowed was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Applies to the entire HEERF program. Questioned costs: None. Repeat finding?: Yes Recommendation: Management should establish and maintain controls over activities allowed or unallowed. View of responsible officials of the auditee: Management agrees with this finding.
2022-003 HEERF Reporting U.S. Department of Education Program Education Stabilization Fund (ESF) subprograms section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) Federal Award Year: 2021?2022 Condition: While testing reporting, we noted that there were not controls or approvals over the reporting requirement for the HEERF program. Criteria: Per 2 CFR part 200.303, ?the non-Federal entity must: a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Effective internal controls should include procedures in place to ensure the proper reviews and approvals are performed over required reporting. Cause: Management did not have effective internal controls in place to ensure that reviews and approvals were performed over the reports due to the newness of the program. In addition, management placed more focus on addressing student needs instead of implementing controls over reporting. Effect: Effective internal control over reporting was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Two out of two reports tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should establish and maintain controls over reporting. View of responsible officials of the auditee: Management agrees with this finding.
2022-001 Enrollment Reporting U.S. Department of Education Program (ED) Student Financial Assistance Programs Cluster Federal Direct Student Loans (ALN 84.268) Federal Perkins Loan Program (ALN 84.038) Federal Award Year: 2021?2022 Condition: Three student?s enrollments changes were not reported to the National Student Loan Data System (NSLDS) within the 60 day timeframe for the School?s reporting on the roster file submissions. Criteria: Per 34 CFR 685.309, Schools are required to accurately report enrollment information under the Direct Loan program via the NSLDS. Enrollment status changes for students should be reported to NSLDS within 30 days, or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the effective change in status or date of determination if the date of determination was determined after the withdrawal date. At a minimum, schools are required to certify enrollment every 60 days. Schools are also responsible for the accurate and timely reporting of high risk program-level record elements, which includes program type, length, and begin date; program enrollment status; and program enrollment effective date. Additionally, schools are required to accurately report enrollment information under the Direct Loan program to the NSLDS site. Cause: Management did not have effective internal controls in place to ensure that compliance with enrollment reporting requirements were followed. For one student?s status change, the National Student Clearinghouse did not submit the enrollment roster to NSLDS in a timely mater. For two students who graduated, the School did not report the students as withdrawn or graduated immediately after the end of the semester and within the required timeframe due to a delay in determining graduation requirements had been satisfied. The School ultimately reported the graduation status to the clearinghouse, but it was not early enough for the clearinghouse to report them on an enrollment roster to NSLDS to be in compliance with the 60 day reporting requirement. Effect: Inaccurate, late reporting may have an effect on timing of conversion to repayment status and/or the amount of repayment for students subject to an interest subsidy. In addition, inaccurate reporting could also cause an over-awarding issue if the student transfers to another school and award determination staff at the subsequent school are unable to accurately determine status and eligibility of the student. Prevalence: Three of the 61 status changes tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should review the controls and procedures in place to verify that accurate, timely and complete data is being submitted to NSLDS. This should include separation of preparation, review and completion, as well as methods to identify an accurate and complete reporting population. View of responsible officials of the auditee: Management agrees with this finding.