Criteria: The Institution must verify that the student remains eligible to receive financial aid prior to disbursement of funds. From appendix A of the compliance supplement: Student must maintain good standing, or satisfactory academic progress (SAP) (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Satisfactory academic progress (SAP) is defined as Maintenance of satisfactory progress (2.0 GPA). Condition: For 12 students with GPA?s under 2.0 of the 43 student files tested receiving financial aid during FY22 selected for testing, there was no evidence of a grant of appeal from SAP requirements prior to disbursement of funds to these students for five of these students. Cause: Weak internal control processes over SAP for students as well as the student appeal process. Effect: For students with a GPA < 2, the University failed to meet its obligation to assist the students with the appeals process. Questioned costs: $38,337 Perspective information: The population was eligibility for Title IV Funds - students must maintain a GPA > 2. The total population (in students) was 1,018. The sample size was 43. The number in sample size with GPA < 2 was 12. The number of exceptions found in the preceding column was 5. Identification of repeat findings: Not a repeat finding. Recommendation: The University should work with the Financial Aid Director to determine the root cause of why students with unsatisfactory academic performance students had no documented appeal process for students to continue to receive aid and develop corrective action as soon as possible to avoid future issues. Views of responsible officials: See Client?s Corrective Action Plan.
Criteria: Institutions are required to report all Direct Loan (DL) disbursements and submit required records to the Department of Education?s Common Origination and Disbursement (COD) which is a web-based system for processing, storing, and reconciling DL financial aid data. Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the Institution?s financial records (?DL Reconciliations?). The University completed a reconciliation at the student level for FY20 and FY21 as part of the audit process and noted $708,695 and $561,172 of direct loan funds that had been posted to student accounts but, did not appear on the student?s COD indicating that a total of $1,269,867 had not been properly processed by the University through the Department of Education and as such, the University had not received these funds to apply to the amounts awarded to student accounts (reimburse the University). To the extent that these issues were corrected, they were reported in the current year SEFA. However, significant issues were still encountered during the FY22 financial statement audit with reconciling direct student loans that resulted in audit adjustments and a passed / unrecorded audit adjustment for the amount that remained unreconciled at the end of FY22 and its financial statement audit completion. Condition: We tested the University?s monthly DL Reconciliation workpaper and noted that the design of the reconciliation process was not sufficient to determine reconciling items at a student level. Cause: The design of the University?s DL Reconciliations appeared to not include determining reconciling items at the student level. Effect: Due to the insufficient DL Reconciliation process, it is likely that the Institution could potentially miss detecting and correcting certain issues or instances of noncompliance in a timely manner. Questioned costs: $-0- Perspective information: The Department of Education requires institutions to reconcile the Direct Loan Program monthly. Identification of repeat findings: Yes, see FA-2021-001. Recommendation: We recommend that the DL Reconciliation process include cooperation between the business and financial aid offices given the financial aid office is the source of information reported to and from COD, and the business office is responsible for the drawdown of funds from the Department of Education?s G5 website as well as for disbursing DL funds to student accounts. At a minimum, the frequency of the DL Reconciliation must be monthly to meet compliance requirements. The financial aid and business offices should first perform an internal reconciliation of their records, identifying any reconciling items at a detailed (student) level. Once this internal reconciliation is complete, the University should perform the external reconciliation to COD?s records via the SAS data file, identifying any reconciling items at a detailed level. Reconciling items from both the internal and external reconciliations should be evaluated for items that require corrective action(s). Corrective actions should be taken timely to correct any issues identified by this process. Finally, cumulative data in G5, such as net drawdowns and net accepted and posted disbursements, should be incorporated into the reconciliation to ensure the University is in compliance with Department of Education?s Cash Management requirements. Further, as a result of the University performing a complete reconciliation for FY20 and FY21, the University should request that the Department of Education provide access to these years that are currently closed so that they can make the corrections required to complete the processing of the student awards not previously properly processed. Views of responsible officials: The University should retain these reconciliations, including all supporting documentation, for purposes of internal and/or external examination. See Client?s Corrective Action Plan.
Criteria: Under the Pell grant and Direct loan programs, institutions are responsible for timely enrollment reporting to NSLDS whether they report directly or via a third-party service such as the National Student Clearinghouse (NSC). Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 60 days whenever enrollment status changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition: We tested NSLDS Enrollment Detail Records for five students with changes in enrollment. For four students of the five, we noted that the student?s enrollment status was not changed in a timely manner for four students. Cause: The enrollment data transmitted to NSC was not accurate. Effect: Enrollment statuses in NSLDS for the affected individuals were not correct and likely resulted in improper loan deferments and interest subsidies on outstanding loans. Questioned costs: $-0- Perspective information: The population was the return of Title IV funds - students with Title IV assistance who officially withdrew and received all failing and/or incomplete grades. The total population (in students) was 57. A sample size of 5. The number in sample size that separated from the University and required a timely change in NSLDS status was 5. The number of exceptions found in the preceding column was 4. Identification of repeat findings: Yes, see FA-2021-002. Recommendation: The University should work with its Information Technology Department and NSC to determine the root cause of the enrollment reporting errors and develop corrective action as soon as possible to avoid future reporting inaccuracies. The corrective action should be closely monitored by the Registrar on test basis to ensure the process is functioning as intended and resulting in accurate enrollment reporting. Views of responsible officials: See Client?s Corrective Action Plan
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b), (1) & 34 CFR 674.42(b)]. Condition: For two of two (all) student files examined where students with direct loans withdrew during FY2022, we did not find satisfactory documentation to show that the University complied with exit counseling requirements. Cause: Weak process and controls over ensuring exit counseling was noted, as well as a lack of recordkeeping to evidence exit counseling requirements were met by the University when a student fails to complete exit counseling online. Effect: For students with a break in enrollment, the University did not meet its responsibilities to provide these individuals with required exit counseling information. Questioned costs: $-0-. Perspective information: The population was the return of Title IV funds - students with Title IV assistance who officially withdrew and received all failing and/or incomplete grades. The total population (in students) was 57. A sample size of 5. The number in sample size that separated from the University and required exit counseling was 2. The number of exceptions found in the preceding column was 2. Identification of repeat findings: Yes, see FA-2021-003. Recommendation: The Financial Aid Director should review the Department of Education?s requirements of institutions related to exit counseling and implement controls to ensure those requirements are met. We recommend that the Department of Education?s Direct Loan Exit Counseling Guide be mailed to the permanent address on record for students who have separated service along with a letter informing them to read the material and perform exit counseling online as a requirement of their federal loans. The materials sent to the students should be dated and copies retained in the students? files as evidence of the University?s compliance. Views of responsible officials: See Client?s Corrective Action Plan.
Criteria: Regulations require the Institution refunds calculated for students who withdrew during a semester be remitted to the Department of Education timely, typically within 45 days of withdrawal. Condition: Five students were selected for withdrawal testwork, and of those five students, the Institution calculated an amount that needed to be returned for four of those students (one student tested did not have to return any federal funds as this student met the requirement to keep all aid received). None of those students who required funds to be returned based upon their withdrawal terms and resulting return of funding calculations were returned timely to the Department of Education. Cause: Weak process and controls over the return of funds for students who withdrew during FY2022. Effect: Funds were held in the University?s cash account longer than necessary and such funds were no longer technically the property of the University after the student withdrew from the University. Questioned costs: $-0- Perspective information: The population was the return of Title IV funds - students with Title IV assistance who officially withdrew and received all failing and/or incomplete grades. The total population (in students) was 57. A sample size of 5. The number in sample size that separated from the University and required return of previously awarded funds to the Department of Education was 4. The number of exceptions found in the preceding column was 4. Identification of repeat findings: Not a repeat finding. Recommendation: The University should increase its efforts through training to ensure that federal refunds are calculated and remitted timely when students withdraw from the Institution. Views of responsible officials: See Client?s Corrective Action Plan.
Criteria: The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the Institution?s website. The forms must be conspicuously posted on the Institution?s primary website on the same page as the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. This information must also be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Condition: We tested two quarterly reports prepared by Virginia Union University to verify timely posting to their website and accuracy in reporting. Of the two tested, we were not able to verify that either had posted timely to the Institution?s website. When we started the compliance audit fieldwork, there was no evidence of the reports on the website. Cause: Weak process and controls over the preparation and review for the compliance over the program?s public reporting requirement. Effect: Potential issues with the DOE regarding noncompliance. Questioned costs: $-0- Perspective information: This finding related to timely posting was identified from testing two of the four required quarterly reports and timely filing could not be verified for either of the 2 reports tested. Identification of repeat findings: Not a repeat finding. Recommendation: The University should increase its efforts to ensure that major program compliance requirements are understood, and controls are implemented to ensure compliance. Views of responsible officials: See Client?s Corrective Action Plan.
Criteria: The compliance supplement indicates that a recipient acknowledges that no supplemental grant funds may be used to fund contractors for the provision of pre-enrollment recruitment activities; marketing or recruitment; endowments; or capital outlays associated with facilities related to athletics, sectarian instruction, or religious worship. Condition: We tested Institutional expenditures for propriety and activities allowed. Two of the 6 Institutional portions of expenditures tested were expenditures for unallowed activities (facilities related to athletics). Cause: Weak process and controls over the preparation and review for the compliance over the activities allowed or unallowed requirement. Effect: Potential issues with the DOE regarding noncompliance. Questioned costs: $527,242 (includes the two expenditures tested and all other related athletic facility expenditures charged to the Institutional portion of the grant during FY22). Perspective information: The population was the HEERF Institutional expenditures expended. The total population (in disbursements) was 89. The sample size was 6. Then umber in the sample with findings was 2. The number of exceptions found in the preceding column was 2. Identification of repeat findings: Not a repeat finding. Recommendation: The University should increase its efforts to ensure that major program compliance requirements are understood, and controls are implemented to ensure compliance. Views of responsible officials: See Client?s Corrective Action Plan.
Criteria: The Institution must verify that the student remains eligible to receive financial aid prior to disbursement of funds. From appendix A of the compliance supplement: Student must maintain good standing, or satisfactory academic progress (SAP) (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Satisfactory academic progress (SAP) is defined as Maintenance of satisfactory progress (2.0 GPA). Condition: For 12 students with GPA?s under 2.0 of the 43 student files tested receiving financial aid during FY22 selected for testing, there was no evidence of a grant of appeal from SAP requirements prior to disbursement of funds to these students for five of these students. Cause: Weak internal control processes over SAP for students as well as the student appeal process. Effect: For students with a GPA < 2, the University failed to meet its obligation to assist the students with the appeals process. Questioned costs: $38,337 Perspective information: The population was eligibility for Title IV Funds - students must maintain a GPA > 2. The total population (in students) was 1,018. The sample size was 43. The number in sample size with GPA < 2 was 12. The number of exceptions found in the preceding column was 5. Identification of repeat findings: Not a repeat finding. Recommendation: The University should work with the Financial Aid Director to determine the root cause of why students with unsatisfactory academic performance students had no documented appeal process for students to continue to receive aid and develop corrective action as soon as possible to avoid future issues. Views of responsible officials: See Client?s Corrective Action Plan.
Criteria: Institutions are required to report all Direct Loan (DL) disbursements and submit required records to the Department of Education?s Common Origination and Disbursement (COD) which is a web-based system for processing, storing, and reconciling DL financial aid data. Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the Institution?s financial records (?DL Reconciliations?). The University completed a reconciliation at the student level for FY20 and FY21 as part of the audit process and noted $708,695 and $561,172 of direct loan funds that had been posted to student accounts but, did not appear on the student?s COD indicating that a total of $1,269,867 had not been properly processed by the University through the Department of Education and as such, the University had not received these funds to apply to the amounts awarded to student accounts (reimburse the University). To the extent that these issues were corrected, they were reported in the current year SEFA. However, significant issues were still encountered during the FY22 financial statement audit with reconciling direct student loans that resulted in audit adjustments and a passed / unrecorded audit adjustment for the amount that remained unreconciled at the end of FY22 and its financial statement audit completion. Condition: We tested the University?s monthly DL Reconciliation workpaper and noted that the design of the reconciliation process was not sufficient to determine reconciling items at a student level. Cause: The design of the University?s DL Reconciliations appeared to not include determining reconciling items at the student level. Effect: Due to the insufficient DL Reconciliation process, it is likely that the Institution could potentially miss detecting and correcting certain issues or instances of noncompliance in a timely manner. Questioned costs: $-0- Perspective information: The Department of Education requires institutions to reconcile the Direct Loan Program monthly. Identification of repeat findings: Yes, see FA-2021-001. Recommendation: We recommend that the DL Reconciliation process include cooperation between the business and financial aid offices given the financial aid office is the source of information reported to and from COD, and the business office is responsible for the drawdown of funds from the Department of Education?s G5 website as well as for disbursing DL funds to student accounts. At a minimum, the frequency of the DL Reconciliation must be monthly to meet compliance requirements. The financial aid and business offices should first perform an internal reconciliation of their records, identifying any reconciling items at a detailed (student) level. Once this internal reconciliation is complete, the University should perform the external reconciliation to COD?s records via the SAS data file, identifying any reconciling items at a detailed level. Reconciling items from both the internal and external reconciliations should be evaluated for items that require corrective action(s). Corrective actions should be taken timely to correct any issues identified by this process. Finally, cumulative data in G5, such as net drawdowns and net accepted and posted disbursements, should be incorporated into the reconciliation to ensure the University is in compliance with Department of Education?s Cash Management requirements. Further, as a result of the University performing a complete reconciliation for FY20 and FY21, the University should request that the Department of Education provide access to these years that are currently closed so that they can make the corrections required to complete the processing of the student awards not previously properly processed. Views of responsible officials: The University should retain these reconciliations, including all supporting documentation, for purposes of internal and/or external examination. See Client?s Corrective Action Plan.
Criteria: Under the Pell grant and Direct loan programs, institutions are responsible for timely enrollment reporting to NSLDS whether they report directly or via a third-party service such as the National Student Clearinghouse (NSC). Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 60 days whenever enrollment status changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition: We tested NSLDS Enrollment Detail Records for five students with changes in enrollment. For four students of the five, we noted that the student?s enrollment status was not changed in a timely manner for four students. Cause: The enrollment data transmitted to NSC was not accurate. Effect: Enrollment statuses in NSLDS for the affected individuals were not correct and likely resulted in improper loan deferments and interest subsidies on outstanding loans. Questioned costs: $-0- Perspective information: The population was the return of Title IV funds - students with Title IV assistance who officially withdrew and received all failing and/or incomplete grades. The total population (in students) was 57. A sample size of 5. The number in sample size that separated from the University and required a timely change in NSLDS status was 5. The number of exceptions found in the preceding column was 4. Identification of repeat findings: Yes, see FA-2021-002. Recommendation: The University should work with its Information Technology Department and NSC to determine the root cause of the enrollment reporting errors and develop corrective action as soon as possible to avoid future reporting inaccuracies. The corrective action should be closely monitored by the Registrar on test basis to ensure the process is functioning as intended and resulting in accurate enrollment reporting. Views of responsible officials: See Client?s Corrective Action Plan
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b), (1) & 34 CFR 674.42(b)]. Condition: For two of two (all) student files examined where students with direct loans withdrew during FY2022, we did not find satisfactory documentation to show that the University complied with exit counseling requirements. Cause: Weak process and controls over ensuring exit counseling was noted, as well as a lack of recordkeeping to evidence exit counseling requirements were met by the University when a student fails to complete exit counseling online. Effect: For students with a break in enrollment, the University did not meet its responsibilities to provide these individuals with required exit counseling information. Questioned costs: $-0-. Perspective information: The population was the return of Title IV funds - students with Title IV assistance who officially withdrew and received all failing and/or incomplete grades. The total population (in students) was 57. A sample size of 5. The number in sample size that separated from the University and required exit counseling was 2. The number of exceptions found in the preceding column was 2. Identification of repeat findings: Yes, see FA-2021-003. Recommendation: The Financial Aid Director should review the Department of Education?s requirements of institutions related to exit counseling and implement controls to ensure those requirements are met. We recommend that the Department of Education?s Direct Loan Exit Counseling Guide be mailed to the permanent address on record for students who have separated service along with a letter informing them to read the material and perform exit counseling online as a requirement of their federal loans. The materials sent to the students should be dated and copies retained in the students? files as evidence of the University?s compliance. Views of responsible officials: See Client?s Corrective Action Plan.
Criteria: Regulations require the Institution refunds calculated for students who withdrew during a semester be remitted to the Department of Education timely, typically within 45 days of withdrawal. Condition: Five students were selected for withdrawal testwork, and of those five students, the Institution calculated an amount that needed to be returned for four of those students (one student tested did not have to return any federal funds as this student met the requirement to keep all aid received). None of those students who required funds to be returned based upon their withdrawal terms and resulting return of funding calculations were returned timely to the Department of Education. Cause: Weak process and controls over the return of funds for students who withdrew during FY2022. Effect: Funds were held in the University?s cash account longer than necessary and such funds were no longer technically the property of the University after the student withdrew from the University. Questioned costs: $-0- Perspective information: The population was the return of Title IV funds - students with Title IV assistance who officially withdrew and received all failing and/or incomplete grades. The total population (in students) was 57. A sample size of 5. The number in sample size that separated from the University and required return of previously awarded funds to the Department of Education was 4. The number of exceptions found in the preceding column was 4. Identification of repeat findings: Not a repeat finding. Recommendation: The University should increase its efforts through training to ensure that federal refunds are calculated and remitted timely when students withdraw from the Institution. Views of responsible officials: See Client?s Corrective Action Plan.
Criteria: The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the Institution?s website. The forms must be conspicuously posted on the Institution?s primary website on the same page as the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. This information must also be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Condition: We tested two quarterly reports prepared by Virginia Union University to verify timely posting to their website and accuracy in reporting. Of the two tested, we were not able to verify that either had posted timely to the Institution?s website. When we started the compliance audit fieldwork, there was no evidence of the reports on the website. Cause: Weak process and controls over the preparation and review for the compliance over the program?s public reporting requirement. Effect: Potential issues with the DOE regarding noncompliance. Questioned costs: $-0- Perspective information: This finding related to timely posting was identified from testing two of the four required quarterly reports and timely filing could not be verified for either of the 2 reports tested. Identification of repeat findings: Not a repeat finding. Recommendation: The University should increase its efforts to ensure that major program compliance requirements are understood, and controls are implemented to ensure compliance. Views of responsible officials: See Client?s Corrective Action Plan.
Criteria: The compliance supplement indicates that a recipient acknowledges that no supplemental grant funds may be used to fund contractors for the provision of pre-enrollment recruitment activities; marketing or recruitment; endowments; or capital outlays associated with facilities related to athletics, sectarian instruction, or religious worship. Condition: We tested Institutional expenditures for propriety and activities allowed. Two of the 6 Institutional portions of expenditures tested were expenditures for unallowed activities (facilities related to athletics). Cause: Weak process and controls over the preparation and review for the compliance over the activities allowed or unallowed requirement. Effect: Potential issues with the DOE regarding noncompliance. Questioned costs: $527,242 (includes the two expenditures tested and all other related athletic facility expenditures charged to the Institutional portion of the grant during FY22). Perspective information: The population was the HEERF Institutional expenditures expended. The total population (in disbursements) was 89. The sample size was 6. Then umber in the sample with findings was 2. The number of exceptions found in the preceding column was 2. Identification of repeat findings: Not a repeat finding. Recommendation: The University should increase its efforts to ensure that major program compliance requirements are understood, and controls are implemented to ensure compliance. Views of responsible officials: See Client?s Corrective Action Plan.