Audit 55292

FY End
2022-06-30
Total Expended
$12.87M
Findings
10
Programs
26
Organization: Trustees of Amherst College (MA)
Year: 2022 Accepted: 2023-03-30

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
58468 2022-001 - - N
58469 2022-001 - - N
58470 2022-001 - - N
58471 2022-002 - - N
58472 2022-003 - - L
634910 2022-001 - - N
634911 2022-001 - - N
634912 2022-001 - - N
634913 2022-002 - - N
634914 2022-003 - - L

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $3.67M Yes 2
84.063 Federal Pell Grant Program $2.53M Yes 1
84.425 Education Stabilization Fund $1.95M Yes 1
47.049 Mathematical and Physical Sciences $900,395 - 0
47.074 Biological Sciences $799,256 - 0
93.859 Biomedical Research and Research Training $504,290 - 0
84.038 Federal Perkins Loan Program $436,512 Yes 0
45.130 Promotion of the Humanities_challenge Grants $320,946 - 0
84.007 Federal Supplemental Educational Opportunity Grants $301,920 Yes 1
84.033 Federal Work-Study Program $254,046 Yes 0
99.U00 Capital Arts Fund $244,097 - 0
45.163 Promotion of the Humanities_professional Development $167,248 - 0
47.075 Social, Behavioral, and Economic Sciences $162,800 - 0
43.001 Science $130,647 - 0
45.301 Museums for America $82,682 - 0
93.865 Child Health and Human Development Extramural Research $61,293 - 0
47.076 Education and Human Resources $45,443 - 0
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $22,827 - 0
47.078 Polar Programs $16,891 - 0
47.050 Geosciences $15,996 - 0
10.310 Agriculture and Food Research Initiative (afri) $15,985 - 0
93.173 Research Related to Deafness and Communication Disorders $14,478 - 0
45.164 Promotion of the Humanities_public Programs $11,858 - 0
45.149 Promotion of the Humanities_division of Preservation and Access $10,090 - 0
45.024 Promotion of the Arts_grants to Organizations and Individuals $8,019 - 0
47.070 Computer and Information Science and Engineering $582 - 0

Contacts

Name Title Type
KDRLUT71AFM5 Thomas Dwyer Auditee
4135425704 Carol Ruiz Auditor
No contacts on file

Notes to SEFA

Title: Federal Student Loan Programs Accounting Policies: BASIS OF PRESENTATION. The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal grant and award transactions of The Trustees of Amherst College (the "Institution") for the year ended June 30, 2022 recorded on the accrual basis. Because the Schedule presents only the federal activity of the Institution, it is not intended to and does not present the financial position, changes in net assets and cash flows of the Institution. The Trustees of Amherst College includes the activities of Amherst College (the "College") and Folger Shakespeare Memorial Library (the "Library").The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Assistance Listing numbers and pass-through entity identification numbers are presented where available. For purposes of the Schedule, federal awards include all grants, contracts and similar agreements entered into directly between the Institution and agencies and departments of the federal government and all sub-awards to the Institution by non-federal organizations pursuant to federal grants, contracts and similar agreements. De Minimis Rate Used: N Rate Explanation: FACILITIES AND ADMINISTRATIVE COST RATE. The Institution's current Facilities and Administrative Costs Rate Agreement went into effect on May 9, 2018. The approved predetermined facilities and administrative cost rates are effective for two distinct time periods. For the effective period of July 1, 2018 through June 30, 2022, the predetermined rates are 54% for on-campus research at the College, 20% for off-campus research at the College, and 76.50% for the Library. The base used to determine the facilities and administrative cost rate for both the College and the Library is direct salaries and wages, including all fringe benefits, and it is drawn from FY17 financial information. The Institution has elected not to use the 10% de minimis indirect cost rate allowed by the Uniform Guidance. The Federal Perkins Loan Program is administered directly by the Institution, and balances and transactions related to this program are included in the Institutions consolidated and individual financial statements. The balance of loans outstanding under the Federal Perkins Loan Program (Assistance Listing Number 84.038) as of June 30, 2022 was $404,216. The Perkins Loan Program line item within the Schedule includes the fiscal year beginning loan balance. The Institution is responsible for certain administrative duties only with respect to the Federal Direct Loan program and, accordingly, these loans are not included in the Institution's consolidated or individual financial statements. It is not practical to determine the balance of loans outstanding under these programs at June 30, 2022.

Finding Details

2022-001 Review of Return of Title IV Funds calculation Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Names: Federal Pell Grant Program, Federal Supplemental Educational Opportunity Grants, Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Numbers: 84.063, 84.007, 84.268 Criteria a) In accordance with 34 CFR section 668.22 (a) (1), when a recipient of the Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of the Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. b) Management has a process in place whereby the Return of Title IV aid calculations are prepared by Assistant Dean of Financial Aid and reviewed by Senior Associate Dean or Dean of Financial Aid. Condition We tested a sample of 5 students who were awarded Title IV aid and withdrew from the College during the fiscal year that required a Return of Title IV aid calculation. For each of the 5 calculations, management performed the calculation accurately, however, there was no evidence noting review and approval by the Senior Associate Dean or Dean of Financial Aid based on management?s process. Cause The College did not retain sufficient evidence of the review performed by management over the Return of Title IV aid calculations. Effect An inaccurate Return of Title IV aid calculation could result in the College returning excess Title IV aid to the Department of Education or disbursing excess Title IV aid to the student in excess of allowable amounts in an untimely manner. Questioned Costs None identified. Recommendation We recommend that the College retain sufficient evidence of the review performed by management over the Return of Title IV funds calculations to ensure that the refunds are accurate. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 Review of Return of Title IV Funds calculation Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Names: Federal Pell Grant Program, Federal Supplemental Educational Opportunity Grants, Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Numbers: 84.063, 84.007, 84.268 Criteria a) In accordance with 34 CFR section 668.22 (a) (1), when a recipient of the Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of the Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. b) Management has a process in place whereby the Return of Title IV aid calculations are prepared by Assistant Dean of Financial Aid and reviewed by Senior Associate Dean or Dean of Financial Aid. Condition We tested a sample of 5 students who were awarded Title IV aid and withdrew from the College during the fiscal year that required a Return of Title IV aid calculation. For each of the 5 calculations, management performed the calculation accurately, however, there was no evidence noting review and approval by the Senior Associate Dean or Dean of Financial Aid based on management?s process. Cause The College did not retain sufficient evidence of the review performed by management over the Return of Title IV aid calculations. Effect An inaccurate Return of Title IV aid calculation could result in the College returning excess Title IV aid to the Department of Education or disbursing excess Title IV aid to the student in excess of allowable amounts in an untimely manner. Questioned Costs None identified. Recommendation We recommend that the College retain sufficient evidence of the review performed by management over the Return of Title IV funds calculations to ensure that the refunds are accurate. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 Review of Return of Title IV Funds calculation Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Names: Federal Pell Grant Program, Federal Supplemental Educational Opportunity Grants, Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Numbers: 84.063, 84.007, 84.268 Criteria a) In accordance with 34 CFR section 668.22 (a) (1), when a recipient of the Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of the Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. b) Management has a process in place whereby the Return of Title IV aid calculations are prepared by Assistant Dean of Financial Aid and reviewed by Senior Associate Dean or Dean of Financial Aid. Condition We tested a sample of 5 students who were awarded Title IV aid and withdrew from the College during the fiscal year that required a Return of Title IV aid calculation. For each of the 5 calculations, management performed the calculation accurately, however, there was no evidence noting review and approval by the Senior Associate Dean or Dean of Financial Aid based on management?s process. Cause The College did not retain sufficient evidence of the review performed by management over the Return of Title IV aid calculations. Effect An inaccurate Return of Title IV aid calculation could result in the College returning excess Title IV aid to the Department of Education or disbursing excess Title IV aid to the student in excess of allowable amounts in an untimely manner. Questioned Costs None identified. Recommendation We recommend that the College retain sufficient evidence of the review performed by management over the Return of Title IV funds calculations to ensure that the refunds are accurate. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-002 Enrollment reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Number: 84.268 Criteria In accordance with 34 CFR 690.83(b)(2) and 685.309, institutions are required to report enrollment information under the Federal Pell Grant (?Pell?) and Federal Direct Loan (?Direct Loan?) programs through the National Student Loan Data System (?NSLDS?). The enrollment information, including Campus Level and Program Level data, must be reviewed, updated, and validated by the institution promptly. Furthermore, specific to the Direct Loan program, for a student that received a Direct Loan and was enrolled or accepted for enrollment at the institution, and the student had ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, the institution must report the change within 60 days from which the change was identified. Management has a review process in place over this compliance requirement. Condition We tested a sample of 25 students that had received either the Federal Pell Grant and/or Federal Direct Loans and had an enrollment status change at the College during the fiscal year. Of the 25 selections, we noted 1 instance in which the student?s withdrawn enrollment status, for a student who received only Federal Direct Loans, was not reported timely to the NSLDS and was not identified as part of management?s review process. The enrollment status change was reported by the College to NSLDS 195 days after the College was aware of the change in enrollment. Additionally, once the change in enrollment was reported to NSLDS by the College, the effective date of the student?s enrollment change per the student?s transcript did not agree to the NSLDS campus level and program level reporting. Cause The College noted the error occurred as a result of an oversight by the individual involved in processing the enrollment status of the student in Colleague, the student information system. The student?s course enrollment for the spring semester was appropriately marked as ?W? on 4/11/2022 when the leave was identified, however the ?Haitus? screen in Colleague was not updated to reflect the status change. Essentially the student withdrew from all courses, but as the ?Haitus? screen was not updated, the enrollment change did not get picked up in the College?s enrollment query for transmission to the NSLDS. Management identified the issue upon review and corrected the status type change and reported to the NSLDS. However, the individual inaccurately reported to the NSLDS an effective date as 5/20/2022, which did not agree to the effective date per the student file of 4/8/2022. Effect The effective administration of Title IV loans could be impacted when changes in students? status are not reported timely. The accuracy of enrollment information is important as the student?s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Department of Education?s payment of interest subsidies. Questioned Costs None identified. Recommendation We recommend the College ensure individuals involved in the process receive additional training over the system and/or business processes and policies to help ensure changes in enrollment information are accurately and timely reported to NSLDS. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-003 Education Stabilization Fund reporting Grantor: Department of Education Award Name: COVID-19 Education Stabilization Fund ? Student Aid Portion Award Year: July 1, 2021 ? June 30, 2022 Award Number: P425E204900 - 20B Assistance Listing Numbers: 84.425E Criteria In accordance with Coronavirus Response and Relief Supplemental Appropriations Act section 314(c)(1), (c)(3), and American Rescue Plan section 2003(5) and Pub. L. No. 117-2 (March 11, 2021), the entity is required to publicly post information no later than 30 days after the award and update that information every calendar quarter and post the report no later than 10 days after the end of each calendar quarter (i.e., Jan 10, April 10, July 10, and October 10). Condition We tested two of four quarterly report submissions that were required during the fiscal year for the student portion of funding received under the Higher Education Emergency Relief program. One of the submissions tested, the April 10th submission, was not submitted by the required deadline and was 14 days late. Cause The late reporting submission was an oversight as a result of turnover in the College?s Student Financial Aid department. Once the oversight was identified, the College filed the submission shortly thereafter. Effect The lack of timely and accurate reports could impact decision making of report users, including the Department of Education and the general public, among others. Questioned Costs None identified. Recommendation We recommend management establish automated reporting reminders that provide a notification to the individual submitting the report that the report is coming due. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 Review of Return of Title IV Funds calculation Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Names: Federal Pell Grant Program, Federal Supplemental Educational Opportunity Grants, Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Numbers: 84.063, 84.007, 84.268 Criteria a) In accordance with 34 CFR section 668.22 (a) (1), when a recipient of the Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of the Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. b) Management has a process in place whereby the Return of Title IV aid calculations are prepared by Assistant Dean of Financial Aid and reviewed by Senior Associate Dean or Dean of Financial Aid. Condition We tested a sample of 5 students who were awarded Title IV aid and withdrew from the College during the fiscal year that required a Return of Title IV aid calculation. For each of the 5 calculations, management performed the calculation accurately, however, there was no evidence noting review and approval by the Senior Associate Dean or Dean of Financial Aid based on management?s process. Cause The College did not retain sufficient evidence of the review performed by management over the Return of Title IV aid calculations. Effect An inaccurate Return of Title IV aid calculation could result in the College returning excess Title IV aid to the Department of Education or disbursing excess Title IV aid to the student in excess of allowable amounts in an untimely manner. Questioned Costs None identified. Recommendation We recommend that the College retain sufficient evidence of the review performed by management over the Return of Title IV funds calculations to ensure that the refunds are accurate. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 Review of Return of Title IV Funds calculation Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Names: Federal Pell Grant Program, Federal Supplemental Educational Opportunity Grants, Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Numbers: 84.063, 84.007, 84.268 Criteria a) In accordance with 34 CFR section 668.22 (a) (1), when a recipient of the Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of the Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. b) Management has a process in place whereby the Return of Title IV aid calculations are prepared by Assistant Dean of Financial Aid and reviewed by Senior Associate Dean or Dean of Financial Aid. Condition We tested a sample of 5 students who were awarded Title IV aid and withdrew from the College during the fiscal year that required a Return of Title IV aid calculation. For each of the 5 calculations, management performed the calculation accurately, however, there was no evidence noting review and approval by the Senior Associate Dean or Dean of Financial Aid based on management?s process. Cause The College did not retain sufficient evidence of the review performed by management over the Return of Title IV aid calculations. Effect An inaccurate Return of Title IV aid calculation could result in the College returning excess Title IV aid to the Department of Education or disbursing excess Title IV aid to the student in excess of allowable amounts in an untimely manner. Questioned Costs None identified. Recommendation We recommend that the College retain sufficient evidence of the review performed by management over the Return of Title IV funds calculations to ensure that the refunds are accurate. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 Review of Return of Title IV Funds calculation Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Names: Federal Pell Grant Program, Federal Supplemental Educational Opportunity Grants, Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Numbers: 84.063, 84.007, 84.268 Criteria a) In accordance with 34 CFR section 668.22 (a) (1), when a recipient of the Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of the Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. b) Management has a process in place whereby the Return of Title IV aid calculations are prepared by Assistant Dean of Financial Aid and reviewed by Senior Associate Dean or Dean of Financial Aid. Condition We tested a sample of 5 students who were awarded Title IV aid and withdrew from the College during the fiscal year that required a Return of Title IV aid calculation. For each of the 5 calculations, management performed the calculation accurately, however, there was no evidence noting review and approval by the Senior Associate Dean or Dean of Financial Aid based on management?s process. Cause The College did not retain sufficient evidence of the review performed by management over the Return of Title IV aid calculations. Effect An inaccurate Return of Title IV aid calculation could result in the College returning excess Title IV aid to the Department of Education or disbursing excess Title IV aid to the student in excess of allowable amounts in an untimely manner. Questioned Costs None identified. Recommendation We recommend that the College retain sufficient evidence of the review performed by management over the Return of Title IV funds calculations to ensure that the refunds are accurate. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-002 Enrollment reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Number: 84.268 Criteria In accordance with 34 CFR 690.83(b)(2) and 685.309, institutions are required to report enrollment information under the Federal Pell Grant (?Pell?) and Federal Direct Loan (?Direct Loan?) programs through the National Student Loan Data System (?NSLDS?). The enrollment information, including Campus Level and Program Level data, must be reviewed, updated, and validated by the institution promptly. Furthermore, specific to the Direct Loan program, for a student that received a Direct Loan and was enrolled or accepted for enrollment at the institution, and the student had ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, the institution must report the change within 60 days from which the change was identified. Management has a review process in place over this compliance requirement. Condition We tested a sample of 25 students that had received either the Federal Pell Grant and/or Federal Direct Loans and had an enrollment status change at the College during the fiscal year. Of the 25 selections, we noted 1 instance in which the student?s withdrawn enrollment status, for a student who received only Federal Direct Loans, was not reported timely to the NSLDS and was not identified as part of management?s review process. The enrollment status change was reported by the College to NSLDS 195 days after the College was aware of the change in enrollment. Additionally, once the change in enrollment was reported to NSLDS by the College, the effective date of the student?s enrollment change per the student?s transcript did not agree to the NSLDS campus level and program level reporting. Cause The College noted the error occurred as a result of an oversight by the individual involved in processing the enrollment status of the student in Colleague, the student information system. The student?s course enrollment for the spring semester was appropriately marked as ?W? on 4/11/2022 when the leave was identified, however the ?Haitus? screen in Colleague was not updated to reflect the status change. Essentially the student withdrew from all courses, but as the ?Haitus? screen was not updated, the enrollment change did not get picked up in the College?s enrollment query for transmission to the NSLDS. Management identified the issue upon review and corrected the status type change and reported to the NSLDS. However, the individual inaccurately reported to the NSLDS an effective date as 5/20/2022, which did not agree to the effective date per the student file of 4/8/2022. Effect The effective administration of Title IV loans could be impacted when changes in students? status are not reported timely. The accuracy of enrollment information is important as the student?s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Department of Education?s payment of interest subsidies. Questioned Costs None identified. Recommendation We recommend the College ensure individuals involved in the process receive additional training over the system and/or business processes and policies to help ensure changes in enrollment information are accurately and timely reported to NSLDS. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-003 Education Stabilization Fund reporting Grantor: Department of Education Award Name: COVID-19 Education Stabilization Fund ? Student Aid Portion Award Year: July 1, 2021 ? June 30, 2022 Award Number: P425E204900 - 20B Assistance Listing Numbers: 84.425E Criteria In accordance with Coronavirus Response and Relief Supplemental Appropriations Act section 314(c)(1), (c)(3), and American Rescue Plan section 2003(5) and Pub. L. No. 117-2 (March 11, 2021), the entity is required to publicly post information no later than 30 days after the award and update that information every calendar quarter and post the report no later than 10 days after the end of each calendar quarter (i.e., Jan 10, April 10, July 10, and October 10). Condition We tested two of four quarterly report submissions that were required during the fiscal year for the student portion of funding received under the Higher Education Emergency Relief program. One of the submissions tested, the April 10th submission, was not submitted by the required deadline and was 14 days late. Cause The late reporting submission was an oversight as a result of turnover in the College?s Student Financial Aid department. Once the oversight was identified, the College filed the submission shortly thereafter. Effect The lack of timely and accurate reports could impact decision making of report users, including the Department of Education and the general public, among others. Questioned Costs None identified. Recommendation We recommend management establish automated reporting reminders that provide a notification to the individual submitting the report that the report is coming due. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.