2022?001 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Fund CFDA Numbers: 84.425 Higher Education Emergency Relief Fund Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: Noncompliance with institutional reporting requirements under HEERF. Questioned costs: None Context: CLA noted that lost revenue was included twice on the March 31, 2022, institutional quarterly report; once in the Replacing lost revenue from academic sources category, and also included in the Other uses of (a)(1) Institutional Portion Funds category. Cause: The University?s policies and procedures did not comply with the reporting requirements under HEERF. Effect: Inaccurate reporting of certain information as noted in the Context above. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate reporting. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022?001 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Fund CFDA Numbers: 84.425 Higher Education Emergency Relief Fund Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: Noncompliance with institutional reporting requirements under HEERF. Questioned costs: None Context: CLA noted that lost revenue was included twice on the March 31, 2022, institutional quarterly report; once in the Replacing lost revenue from academic sources category, and also included in the Other uses of (a)(1) Institutional Portion Funds category. Cause: The University?s policies and procedures did not comply with the reporting requirements under HEERF. Effect: Inaccurate reporting of certain information as noted in the Context above. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate reporting. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022?002 Return to Title IV (R2T4) Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 34 CFR 668.22(g)(ii)(2) institutional charges are tuition, fees, room and board (if the student contracts with the institution for the room and board), and other educationally-related expenses assessed by the institution. Condition: During our testing, we noted one instance out of forty students tested, where the R2T4 calculation performed by the Institution did not exclude the correct amount of days for scheduled breaks of five days or more. In addition, we noted two instances out of forty students tested, where incorrect institutional charges were utilized in the calculation. Questioned Costs: These errors resulted in excess refunds to the Department of Education totaling $178. This amount includes $187 of excess refunds of direct loan funds, offset by $9 of additional Pell funds that should have been returned. Context: Incorrect inputs in the R2T4 calculation resulted in the calculation discrepancies. Cause: The University does not have policies and procedures in place to ensure calculations are properly performed. Effect: The University returned excess funds to the Department of Education. Repeat Finding: No Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are completed accurately. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022?002 Return to Title IV (R2T4) Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 34 CFR 668.22(g)(ii)(2) institutional charges are tuition, fees, room and board (if the student contracts with the institution for the room and board), and other educationally-related expenses assessed by the institution. Condition: During our testing, we noted one instance out of forty students tested, where the R2T4 calculation performed by the Institution did not exclude the correct amount of days for scheduled breaks of five days or more. In addition, we noted two instances out of forty students tested, where incorrect institutional charges were utilized in the calculation. Questioned Costs: These errors resulted in excess refunds to the Department of Education totaling $178. This amount includes $187 of excess refunds of direct loan funds, offset by $9 of additional Pell funds that should have been returned. Context: Incorrect inputs in the R2T4 calculation resulted in the calculation discrepancies. Cause: The University does not have policies and procedures in place to ensure calculations are properly performed. Effect: The University returned excess funds to the Department of Education. Repeat Finding: No Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are completed accurately. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022?003 ? NSLDS Enrollment Reporting Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding related to Compliance and Significant Deficiency in Internal Controls over Compliance. Criteria or Specific Requirement: Institutions are required to report, certify, and correct enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. Institutions must return the roster within 15 days of receipt, and correct errors within 10 days of receipt. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected the annual SCHER 1 report and a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted 11 instances of noncompliance related to the SCHER1 report, and 34 of 40 students tested had one or more instances of noncompliance, as noted below: I. Eleven instances where the Institution did not correct errors within the required ten days. When the errors were reported back to the servicer, the resubmission of the records were not corrected and ultimately rejected again. II. Thirty-one instances where the student's program begin date reported to NSLDS did not agree to the Institution's records. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) III. Twenty instances where the student?s program enrollment effective date was incorrectly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) IV. Three instances where the student's change in statuses were not certified and/or received by NSLDS within the required sixty days. 34 CFR 674.19(f)(2) Questioned Costs: None Context: Out of a sample of 40 students selected for testing, and 1 SCHER1 report for the requirements noted above, we noted the exceptions as described above. Cause: The University?s processes and controls did not ensure that student status changes were properly reported to NSLDS and errors corrected timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the Institution review its reporting procedures to ensure that students? statuses are accurately reported to NSLDS as required by regulations. In addition, we recommend the Institution work with its servicer to determine a procedure is in place to ensure all rejected records are properly reported to NSLDS within 10 days of the initial roster certification and upload. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022?001 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Fund CFDA Numbers: 84.425 Higher Education Emergency Relief Fund Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: Noncompliance with institutional reporting requirements under HEERF. Questioned costs: None Context: CLA noted that lost revenue was included twice on the March 31, 2022, institutional quarterly report; once in the Replacing lost revenue from academic sources category, and also included in the Other uses of (a)(1) Institutional Portion Funds category. Cause: The University?s policies and procedures did not comply with the reporting requirements under HEERF. Effect: Inaccurate reporting of certain information as noted in the Context above. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate reporting. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022?001 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Fund CFDA Numbers: 84.425 Higher Education Emergency Relief Fund Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: Noncompliance with institutional reporting requirements under HEERF. Questioned costs: None Context: CLA noted that lost revenue was included twice on the March 31, 2022, institutional quarterly report; once in the Replacing lost revenue from academic sources category, and also included in the Other uses of (a)(1) Institutional Portion Funds category. Cause: The University?s policies and procedures did not comply with the reporting requirements under HEERF. Effect: Inaccurate reporting of certain information as noted in the Context above. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate reporting. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022?001 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Fund CFDA Numbers: 84.425 Higher Education Emergency Relief Fund Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: Noncompliance with institutional reporting requirements under HEERF. Questioned costs: None Context: CLA noted that lost revenue was included twice on the March 31, 2022, institutional quarterly report; once in the Replacing lost revenue from academic sources category, and also included in the Other uses of (a)(1) Institutional Portion Funds category. Cause: The University?s policies and procedures did not comply with the reporting requirements under HEERF. Effect: Inaccurate reporting of certain information as noted in the Context above. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate reporting. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022?002 Return to Title IV (R2T4) Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 34 CFR 668.22(g)(ii)(2) institutional charges are tuition, fees, room and board (if the student contracts with the institution for the room and board), and other educationally-related expenses assessed by the institution. Condition: During our testing, we noted one instance out of forty students tested, where the R2T4 calculation performed by the Institution did not exclude the correct amount of days for scheduled breaks of five days or more. In addition, we noted two instances out of forty students tested, where incorrect institutional charges were utilized in the calculation. Questioned Costs: These errors resulted in excess refunds to the Department of Education totaling $178. This amount includes $187 of excess refunds of direct loan funds, offset by $9 of additional Pell funds that should have been returned. Context: Incorrect inputs in the R2T4 calculation resulted in the calculation discrepancies. Cause: The University does not have policies and procedures in place to ensure calculations are properly performed. Effect: The University returned excess funds to the Department of Education. Repeat Finding: No Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are completed accurately. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022?002 Return to Title IV (R2T4) Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 34 CFR 668.22(g)(ii)(2) institutional charges are tuition, fees, room and board (if the student contracts with the institution for the room and board), and other educationally-related expenses assessed by the institution. Condition: During our testing, we noted one instance out of forty students tested, where the R2T4 calculation performed by the Institution did not exclude the correct amount of days for scheduled breaks of five days or more. In addition, we noted two instances out of forty students tested, where incorrect institutional charges were utilized in the calculation. Questioned Costs: These errors resulted in excess refunds to the Department of Education totaling $178. This amount includes $187 of excess refunds of direct loan funds, offset by $9 of additional Pell funds that should have been returned. Context: Incorrect inputs in the R2T4 calculation resulted in the calculation discrepancies. Cause: The University does not have policies and procedures in place to ensure calculations are properly performed. Effect: The University returned excess funds to the Department of Education. Repeat Finding: No Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are completed accurately. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022?003 ? NSLDS Enrollment Reporting Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding related to Compliance and Significant Deficiency in Internal Controls over Compliance. Criteria or Specific Requirement: Institutions are required to report, certify, and correct enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. Institutions must return the roster within 15 days of receipt, and correct errors within 10 days of receipt. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected the annual SCHER 1 report and a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted 11 instances of noncompliance related to the SCHER1 report, and 34 of 40 students tested had one or more instances of noncompliance, as noted below: I. Eleven instances where the Institution did not correct errors within the required ten days. When the errors were reported back to the servicer, the resubmission of the records were not corrected and ultimately rejected again. II. Thirty-one instances where the student's program begin date reported to NSLDS did not agree to the Institution's records. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) III. Twenty instances where the student?s program enrollment effective date was incorrectly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) IV. Three instances where the student's change in statuses were not certified and/or received by NSLDS within the required sixty days. 34 CFR 674.19(f)(2) Questioned Costs: None Context: Out of a sample of 40 students selected for testing, and 1 SCHER1 report for the requirements noted above, we noted the exceptions as described above. Cause: The University?s processes and controls did not ensure that student status changes were properly reported to NSLDS and errors corrected timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the Institution review its reporting procedures to ensure that students? statuses are accurately reported to NSLDS as required by regulations. In addition, we recommend the Institution work with its servicer to determine a procedure is in place to ensure all rejected records are properly reported to NSLDS within 10 days of the initial roster certification and upload. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022?001 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Fund CFDA Numbers: 84.425 Higher Education Emergency Relief Fund Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: Noncompliance with institutional reporting requirements under HEERF. Questioned costs: None Context: CLA noted that lost revenue was included twice on the March 31, 2022, institutional quarterly report; once in the Replacing lost revenue from academic sources category, and also included in the Other uses of (a)(1) Institutional Portion Funds category. Cause: The University?s policies and procedures did not comply with the reporting requirements under HEERF. Effect: Inaccurate reporting of certain information as noted in the Context above. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate reporting. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.