Finding 2022-001 Federal program: Education Stabilization Fund -Higher Education Emergency Relief Fund (HEERF): COVID-19 CARES Act- Student Aid Portion AL #: 84.425E Award Year: 2021/2022 Type of finding: Deficiency and Noncompliance Compliance requirement: Reporting - Special Reporting Criteria: Under 2 CFR 200.328 and 200.329, Universities must publicly post certain information relating to Student Aid awards on their website no later than 30 days after award, and update that information within 10 days after the end of every calendar quarter by posting a new report. Condition: Due to the timing of the prior year finding being identified, the award notification report, and first and second quarter reports for FY 2022 were also not posted timely as required. No issues were noted with the accuracy of the disclosure, but the timing was past the required due date. Questioned costs: None Context: The Student Aid grant awards were not reported on the University?s website on a timely basis for the first and second quarters of FY22. Cause: The University established reporting processes according to the compliance supplement. However, in the process of assigning responsibility for each reporting requirement, this requirement of updating the HEERF award disclosures quarterly was missed. Effect: The HEERF Student Aid award information was not reported publicly on the University?s website. As a result, students and other interested parties did not have readily presented access to this data. Repeat finding: Yes ? 2021-001. The finding is limited to the HEERF Student Aid first and second quarter reporting of FY22. Recommendations: We recommend that the University have controls in place to ensure that all required reporting is performed timely. Views of responsible officials: HEERF was issued to institutions of higher education in the spring of 2020 to support students and campus operations in the midst of the COVID-19 pandemic. Quarterly reporting requirements were later established by the Department of Education. Student Aid grant award reporting was overlooked by the responsible official due to confusion of duty with the emergency relief program. When the prior-year finding was identified, a system of controls was established to ensure future compliance and timely reporting. Specifically, the responsible reporting officials for the institutional and student portions of HEERF funding combined report information into a single web posting request prior to the deadline each quarter. This single request provided another check for the posting official to confirm the quarterly report was comprehensive.
Finding 2022-002 Federal program: Student Financial Assistance Cluster AL #: 84.038 Award Year: 2021/2022 Type of finding: Deficiency and Noncompliance Compliance requirement: Special Tests - Perkins Loan Recordkeeping and Record Retention Criteria: Under 34 CFR 674.19.(e), institutions must retain original or true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan (including Defense, NDSL) made. Additionally, an institution shall retain repayment records, including cancellation and deferment requests for at least three years from the date on which a loan is assigned to the secretary, canceled, or repaid. An institution shall retain disbursement and electronic authentication and signature records for each loan made using an MPN for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. Condition: The original MPN was not retained for one of the 16 judgmentally selected loans that were assigned in the previous three fiscal years and current fiscal year. The University had already identified nine missing MPNs in their loan assignment process, an additional eight to our one finding. We then expanded our sample, excluding these eight known missing MPNs, and tested an additional eight selections, noting no additional errors. Questioned costs: None Context: The University failed to maintain true and exact copies of MPNs. Cause: The University did not have a policy in place prior to 2005 when they began using a third-party servicer to ensure MPNs were retained for students. Effect: Not maintaining the original MPN for a student could cause problems with verifying the existence of the associated loan and any legally required repayment. This could also cause the University to purchase the loan. Repeat finding: No. Recommendations: We recommend that the University have controls in place to ensure that all required documentation is retained in compliance with Perkins Loan requirements. Views of responsible officials: The current policy requires a master promissory note (MPN) to be stored in a locked, fireproof safe. The University acknowledges there may have been gaps in internal controls during the 1970s and 1980s resulting in the missing MPN. Since 2005, MPNs are electronically signed and maintained by ECSI, the third-party servicer. During 2022, Trinity submitted 154 loans to the Department of Education (DOE) for assignment. While the University did not have an MPN for nine of these loans, the DOE accepted all but one loan based on additional documentation provided in lieu of an MPN. To determine potential future exposure, the University reviewed paper files for the 25 borrowers with loans disbursed prior to 2005 and found only three additional borrowers with a missing MPN. If the University were required to purchase these loans from the DOE, the estimated purchase amount would be less than $30,000.
Finding 2022-001 Federal program: Education Stabilization Fund -Higher Education Emergency Relief Fund (HEERF): COVID-19 CARES Act- Student Aid Portion AL #: 84.425E Award Year: 2021/2022 Type of finding: Deficiency and Noncompliance Compliance requirement: Reporting - Special Reporting Criteria: Under 2 CFR 200.328 and 200.329, Universities must publicly post certain information relating to Student Aid awards on their website no later than 30 days after award, and update that information within 10 days after the end of every calendar quarter by posting a new report. Condition: Due to the timing of the prior year finding being identified, the award notification report, and first and second quarter reports for FY 2022 were also not posted timely as required. No issues were noted with the accuracy of the disclosure, but the timing was past the required due date. Questioned costs: None Context: The Student Aid grant awards were not reported on the University?s website on a timely basis for the first and second quarters of FY22. Cause: The University established reporting processes according to the compliance supplement. However, in the process of assigning responsibility for each reporting requirement, this requirement of updating the HEERF award disclosures quarterly was missed. Effect: The HEERF Student Aid award information was not reported publicly on the University?s website. As a result, students and other interested parties did not have readily presented access to this data. Repeat finding: Yes ? 2021-001. The finding is limited to the HEERF Student Aid first and second quarter reporting of FY22. Recommendations: We recommend that the University have controls in place to ensure that all required reporting is performed timely. Views of responsible officials: HEERF was issued to institutions of higher education in the spring of 2020 to support students and campus operations in the midst of the COVID-19 pandemic. Quarterly reporting requirements were later established by the Department of Education. Student Aid grant award reporting was overlooked by the responsible official due to confusion of duty with the emergency relief program. When the prior-year finding was identified, a system of controls was established to ensure future compliance and timely reporting. Specifically, the responsible reporting officials for the institutional and student portions of HEERF funding combined report information into a single web posting request prior to the deadline each quarter. This single request provided another check for the posting official to confirm the quarterly report was comprehensive.
Finding 2022-002 Federal program: Student Financial Assistance Cluster AL #: 84.038 Award Year: 2021/2022 Type of finding: Deficiency and Noncompliance Compliance requirement: Special Tests - Perkins Loan Recordkeeping and Record Retention Criteria: Under 34 CFR 674.19.(e), institutions must retain original or true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan (including Defense, NDSL) made. Additionally, an institution shall retain repayment records, including cancellation and deferment requests for at least three years from the date on which a loan is assigned to the secretary, canceled, or repaid. An institution shall retain disbursement and electronic authentication and signature records for each loan made using an MPN for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. Condition: The original MPN was not retained for one of the 16 judgmentally selected loans that were assigned in the previous three fiscal years and current fiscal year. The University had already identified nine missing MPNs in their loan assignment process, an additional eight to our one finding. We then expanded our sample, excluding these eight known missing MPNs, and tested an additional eight selections, noting no additional errors. Questioned costs: None Context: The University failed to maintain true and exact copies of MPNs. Cause: The University did not have a policy in place prior to 2005 when they began using a third-party servicer to ensure MPNs were retained for students. Effect: Not maintaining the original MPN for a student could cause problems with verifying the existence of the associated loan and any legally required repayment. This could also cause the University to purchase the loan. Repeat finding: No. Recommendations: We recommend that the University have controls in place to ensure that all required documentation is retained in compliance with Perkins Loan requirements. Views of responsible officials: The current policy requires a master promissory note (MPN) to be stored in a locked, fireproof safe. The University acknowledges there may have been gaps in internal controls during the 1970s and 1980s resulting in the missing MPN. Since 2005, MPNs are electronically signed and maintained by ECSI, the third-party servicer. During 2022, Trinity submitted 154 loans to the Department of Education (DOE) for assignment. While the University did not have an MPN for nine of these loans, the DOE accepted all but one loan based on additional documentation provided in lieu of an MPN. To determine potential future exposure, the University reviewed paper files for the 25 borrowers with loans disbursed prior to 2005 and found only three additional borrowers with a missing MPN. If the University were required to purchase these loans from the DOE, the estimated purchase amount would be less than $30,000.