Audit 73872

FY End
2022-06-30
Total Expended
$34.66M
Findings
48
Programs
10
Organization: Eastern University (PA)
Year: 2022 Accepted: 2023-03-27
Auditor: Capincrouse LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
64471 2022-001 Material Weakness - N
64472 2022-002 Material Weakness - N
64473 2022-005 - - E
64474 2022-006 - - N
64475 2022-001 Material Weakness - N
64476 2022-002 Material Weakness - N
64477 2022-004 Significant Deficiency - E
64478 2022-005 - - E
64479 2022-006 - - N
64480 2022-001 Material Weakness - N
64481 2022-002 Material Weakness - N
64482 2022-005 - - E
64483 2022-006 - - N
64484 2022-001 Material Weakness - N
64485 2022-005 - - E
64486 2022-006 - - N
64487 2022-001 Material Weakness - N
64488 2022-001 Material Weakness - N
64489 2022-002 Material Weakness - N
64490 2022-005 - - E
64491 2022-006 - - N
64492 2022-003 Material Weakness - L
64493 2022-003 Material Weakness - L
64494 2022-003 Material Weakness - L
640913 2022-001 Material Weakness - N
640914 2022-002 Material Weakness - N
640915 2022-005 - - E
640916 2022-006 - - N
640917 2022-001 Material Weakness - N
640918 2022-002 Material Weakness - N
640919 2022-004 Significant Deficiency - E
640920 2022-005 - - E
640921 2022-006 - - N
640922 2022-001 Material Weakness - N
640923 2022-002 Material Weakness - N
640924 2022-005 - - E
640925 2022-006 - - N
640926 2022-001 Material Weakness - N
640927 2022-005 - - E
640928 2022-006 - - N
640929 2022-001 Material Weakness - N
640930 2022-001 Material Weakness - N
640931 2022-002 Material Weakness - N
640932 2022-005 - - E
640933 2022-006 - - N
640934 2022-003 Material Weakness - L
640935 2022-003 Material Weakness - L
640936 2022-003 Material Weakness - L

Contacts

Name Title Type
HEJ8RLLYCJH5 Trevor Jackson Auditee
6102255699 Fran Brown, CPA Auditor
No contacts on file

Notes to SEFA

Title: RELATIONSHIP TO FINANCIAL STATEMENTS Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Eastern University (University) under programs of the federal government for the year ending June 30, 2022. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: Y Rate Explanation: The auditee used the de minimis cost rate. See table in SEFA Note 3.
Title: SUBRECIPIENTS, NON-CASH ASSISTANCE, FEDERAL INSURANCE, LOANS, AND LOAN GUAR Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Eastern University (University) under programs of the federal government for the year ending June 30, 2022. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: Y Rate Explanation: The auditee used the de minimis cost rate. The University did not provide any federal funds to subrecipients nor did they receive any federal non-cash assistance, insurance, loans, or loan guarantees.
Title: FEDERAL PERKINS LOAN PROGRAM Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Eastern University (University) under programs of the federal government for the year ending June 30, 2022. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: Y Rate Explanation: The auditee used the de minimis cost rate. See table in SEFA Note 5.

Finding Details

Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The transmission of information from the online platform included activity that did not meet the definition of academic activity resulting in students not having a correct calculation performed. Additionally, the new modular regulations were not correctly applied. Criteria: 34 CFR 668.22 Questioned Costs: $29,626 Context: Out of 31 students, 16 students who withdrew during the audit period tested had an incorrect return or lack of return. Four students did not have academic activity as defined in the regulation for their online course, and all funds should be returned for that term. Nine students, of which the majority was online modular students not a meeting withdrawal exemption, did not complete past 60% of the semester and should have had funds returned. Two students did not have academic activity as defined in the regulations for an online course and should have had Pell recalculated. One student had an incorrect calculation due to an incorrect scheduled break calculation. Cause: The programming in the online platform for meeting the definition of academic activity was not accurately set up for the 2021-2022 award year and inadvertently included any activity such as just logging in. If the student attended a second module without completing the first module, all days of the first module were counted as attended instead of the actual attended days. There was an oversight in a calendar set up for a scheduled break as well as using the date of determination as the withdrawal date rather than the last date of attendance. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs and incorrect returns. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the programming of the transmission of confirming attendance be specific to the regulations. We further recommend that federal aid is not disbursed to a student until academic activity in a class has been confirmed. We recommend the last date of academic activity be shared with the financial aid team systematically so calculations on all 0 credit students can be done timely. Should a student not begin attendance in an online class, we recommend the Pell be recalculated and returned immediately. We further recommend an additional layer of review on the calendar set up process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Appeals DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University missed requiring a formal satisfactory academic progress (SAP) appeals for one student. Criteria: 34 CFR 668.34(c) Questioned Costs: $7,676 Context: 1 student out of 12 tested was awarded federal aid but was ineligible due to not making SAP and did not have an approved appeal to reinstate eligibility. The University returned the federal aid during the audit process. Cause: There was an oversight of requiring an appeal for a student not making SAP. Effect: An ineligible student was awarded federal aid. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University ensure those students who were not meeting SAP have an approved appeal documented prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students selected for V4 verification inappropriately had the full V1 waiver applied. Criteria: 34 CFR 668.56 Questioned Costs: $10,374 Context: Out of 6 tested for the V4 or V5 flag of verification, 2 students did not have a statement of educational purpose on file. These students were corrected during the audit process. Cause: The waiver for verification only applied to the V1 portion of the flag but was inadvertently applied to the whole V4 flag. Effect: These students were not eligible for federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University obtain the signed statement of educational purpose, ID, and required transcripts for the V4 flag prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The transmission of information from the online platform included activity that did not meet the definition of academic activity resulting in students not having a correct calculation performed. Additionally, the new modular regulations were not correctly applied. Criteria: 34 CFR 668.22 Questioned Costs: $29,626 Context: Out of 31 students, 16 students who withdrew during the audit period tested had an incorrect return or lack of return. Four students did not have academic activity as defined in the regulation for their online course, and all funds should be returned for that term. Nine students, of which the majority was online modular students not a meeting withdrawal exemption, did not complete past 60% of the semester and should have had funds returned. Two students did not have academic activity as defined in the regulations for an online course and should have had Pell recalculated. One student had an incorrect calculation due to an incorrect scheduled break calculation. Cause: The programming in the online platform for meeting the definition of academic activity was not accurately set up for the 2021-2022 award year and inadvertently included any activity such as just logging in. If the student attended a second module without completing the first module, all days of the first module were counted as attended instead of the actual attended days. There was an oversight in a calendar set up for a scheduled break as well as using the date of determination as the withdrawal date rather than the last date of attendance. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs and incorrect returns. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the programming of the transmission of confirming attendance be specific to the regulations. We further recommend that federal aid is not disbursed to a student until academic activity in a class has been confirmed. We recommend the last date of academic activity be shared with the financial aid team systematically so calculations on all 0 credit students can be done timely. Should a student not begin attendance in an online class, we recommend the Pell be recalculated and returned immediately. We further recommend an additional layer of review on the calendar set up process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: 3 students out of 32 were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $-0- Context: Two students were student teaching in one semester and were not properly classified as traditional students during that semester, resulting in underawards of Pell of $2,018. Additionally, one student was incorrectly classified for the summer sessions and was underawarded Pell of $1,625. Cause: One financial aid counselor did not identify the transition in student type to apply the correct Pell formula. Effect: There was an incorrect amount of Pell paid to these three students. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend a process be used to adjust the Pell formula used to be in alignment with the type of student for that semester. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Appeals DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University missed requiring a formal satisfactory academic progress (SAP) appeals for one student. Criteria: 34 CFR 668.34(c) Questioned Costs: $7,676 Context: 1 student out of 12 tested was awarded federal aid but was ineligible due to not making SAP and did not have an approved appeal to reinstate eligibility. The University returned the federal aid during the audit process. Cause: There was an oversight of requiring an appeal for a student not making SAP. Effect: An ineligible student was awarded federal aid. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University ensure those students who were not meeting SAP have an approved appeal documented prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students selected for V4 verification inappropriately had the full V1 waiver applied. Criteria: 34 CFR 668.56 Questioned Costs: $10,374 Context: Out of 6 tested for the V4 or V5 flag of verification, 2 students did not have a statement of educational purpose on file. These students were corrected during the audit process. Cause: The waiver for verification only applied to the V1 portion of the flag but was inadvertently applied to the whole V4 flag. Effect: These students were not eligible for federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University obtain the signed statement of educational purpose, ID, and required transcripts for the V4 flag prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The transmission of information from the online platform included activity that did not meet the definition of academic activity resulting in students not having a correct calculation performed. Additionally, the new modular regulations were not correctly applied. Criteria: 34 CFR 668.22 Questioned Costs: $29,626 Context: Out of 31 students, 16 students who withdrew during the audit period tested had an incorrect return or lack of return. Four students did not have academic activity as defined in the regulation for their online course, and all funds should be returned for that term. Nine students, of which the majority was online modular students not a meeting withdrawal exemption, did not complete past 60% of the semester and should have had funds returned. Two students did not have academic activity as defined in the regulations for an online course and should have had Pell recalculated. One student had an incorrect calculation due to an incorrect scheduled break calculation. Cause: The programming in the online platform for meeting the definition of academic activity was not accurately set up for the 2021-2022 award year and inadvertently included any activity such as just logging in. If the student attended a second module without completing the first module, all days of the first module were counted as attended instead of the actual attended days. There was an oversight in a calendar set up for a scheduled break as well as using the date of determination as the withdrawal date rather than the last date of attendance. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs and incorrect returns. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the programming of the transmission of confirming attendance be specific to the regulations. We further recommend that federal aid is not disbursed to a student until academic activity in a class has been confirmed. We recommend the last date of academic activity be shared with the financial aid team systematically so calculations on all 0 credit students can be done timely. Should a student not begin attendance in an online class, we recommend the Pell be recalculated and returned immediately. We further recommend an additional layer of review on the calendar set up process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Appeals DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University missed requiring a formal satisfactory academic progress (SAP) appeals for one student. Criteria: 34 CFR 668.34(c) Questioned Costs: $7,676 Context: 1 student out of 12 tested was awarded federal aid but was ineligible due to not making SAP and did not have an approved appeal to reinstate eligibility. The University returned the federal aid during the audit process. Cause: There was an oversight of requiring an appeal for a student not making SAP. Effect: An ineligible student was awarded federal aid. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University ensure those students who were not meeting SAP have an approved appeal documented prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students selected for V4 verification inappropriately had the full V1 waiver applied. Criteria: 34 CFR 668.56 Questioned Costs: $10,374 Context: Out of 6 tested for the V4 or V5 flag of verification, 2 students did not have a statement of educational purpose on file. These students were corrected during the audit process. Cause: The waiver for verification only applied to the V1 portion of the flag but was inadvertently applied to the whole V4 flag. Effect: These students were not eligible for federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University obtain the signed statement of educational purpose, ID, and required transcripts for the V4 flag prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Appeals DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University missed requiring a formal satisfactory academic progress (SAP) appeals for one student. Criteria: 34 CFR 668.34(c) Questioned Costs: $7,676 Context: 1 student out of 12 tested was awarded federal aid but was ineligible due to not making SAP and did not have an approved appeal to reinstate eligibility. The University returned the federal aid during the audit process. Cause: There was an oversight of requiring an appeal for a student not making SAP. Effect: An ineligible student was awarded federal aid. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University ensure those students who were not meeting SAP have an approved appeal documented prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students selected for V4 verification inappropriately had the full V1 waiver applied. Criteria: 34 CFR 668.56 Questioned Costs: $10,374 Context: Out of 6 tested for the V4 or V5 flag of verification, 2 students did not have a statement of educational purpose on file. These students were corrected during the audit process. Cause: The waiver for verification only applied to the V1 portion of the flag but was inadvertently applied to the whole V4 flag. Effect: These students were not eligible for federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University obtain the signed statement of educational purpose, ID, and required transcripts for the V4 flag prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The transmission of information from the online platform included activity that did not meet the definition of academic activity resulting in students not having a correct calculation performed. Additionally, the new modular regulations were not correctly applied. Criteria: 34 CFR 668.22 Questioned Costs: $29,626 Context: Out of 31 students, 16 students who withdrew during the audit period tested had an incorrect return or lack of return. Four students did not have academic activity as defined in the regulation for their online course, and all funds should be returned for that term. Nine students, of which the majority was online modular students not a meeting withdrawal exemption, did not complete past 60% of the semester and should have had funds returned. Two students did not have academic activity as defined in the regulations for an online course and should have had Pell recalculated. One student had an incorrect calculation due to an incorrect scheduled break calculation. Cause: The programming in the online platform for meeting the definition of academic activity was not accurately set up for the 2021-2022 award year and inadvertently included any activity such as just logging in. If the student attended a second module without completing the first module, all days of the first module were counted as attended instead of the actual attended days. There was an oversight in a calendar set up for a scheduled break as well as using the date of determination as the withdrawal date rather than the last date of attendance. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs and incorrect returns. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the programming of the transmission of confirming attendance be specific to the regulations. We further recommend that federal aid is not disbursed to a student until academic activity in a class has been confirmed. We recommend the last date of academic activity be shared with the financial aid team systematically so calculations on all 0 credit students can be done timely. Should a student not begin attendance in an online class, we recommend the Pell be recalculated and returned immediately. We further recommend an additional layer of review on the calendar set up process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Appeals DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University missed requiring a formal satisfactory academic progress (SAP) appeals for one student. Criteria: 34 CFR 668.34(c) Questioned Costs: $7,676 Context: 1 student out of 12 tested was awarded federal aid but was ineligible due to not making SAP and did not have an approved appeal to reinstate eligibility. The University returned the federal aid during the audit process. Cause: There was an oversight of requiring an appeal for a student not making SAP. Effect: An ineligible student was awarded federal aid. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University ensure those students who were not meeting SAP have an approved appeal documented prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students selected for V4 verification inappropriately had the full V1 waiver applied. Criteria: 34 CFR 668.56 Questioned Costs: $10,374 Context: Out of 6 tested for the V4 or V5 flag of verification, 2 students did not have a statement of educational purpose on file. These students were corrected during the audit process. Cause: The waiver for verification only applied to the V1 portion of the flag but was inadvertently applied to the whole V4 flag. Effect: These students were not eligible for federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University obtain the signed statement of educational purpose, ID, and required transcripts for the V4 flag prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund Reporting Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.425E, 84.425F, 84.425L Federal Award Identification #: P425E202018, P425F202629, P425L200204 Condition: The University did not accurately report their student grant information and institutional expenditures on the HEERF Annual Report for the calendar year 2021. Criteria: 2 CFR 200.329 Questioned Costs: $-0- Context: During the audit, it was identified that the University did not accurately report the total student grants and institutional expenses in the HEERF annual report. The University reviewed what was reported and corrected the report during the audit process. Cause: There was a transition in the key personnel completing the annual report, and part of the information used did not have the correct parameters for the calendar year 2021. Effect: The amounts reported on the annual report to the Department did not agree to the underlying records of the University or the quarterly reports prepared by the University. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University amend the 2021 annual report when the 2022 reporting cycle opens up the portal. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund Reporting Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.425E, 84.425F, 84.425L Federal Award Identification #: P425E202018, P425F202629, P425L200204 Condition: The University did not accurately report their student grant information and institutional expenditures on the HEERF Annual Report for the calendar year 2021. Criteria: 2 CFR 200.329 Questioned Costs: $-0- Context: During the audit, it was identified that the University did not accurately report the total student grants and institutional expenses in the HEERF annual report. The University reviewed what was reported and corrected the report during the audit process. Cause: There was a transition in the key personnel completing the annual report, and part of the information used did not have the correct parameters for the calendar year 2021. Effect: The amounts reported on the annual report to the Department did not agree to the underlying records of the University or the quarterly reports prepared by the University. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University amend the 2021 annual report when the 2022 reporting cycle opens up the portal. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund Reporting Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.425E, 84.425F, 84.425L Federal Award Identification #: P425E202018, P425F202629, P425L200204 Condition: The University did not accurately report their student grant information and institutional expenditures on the HEERF Annual Report for the calendar year 2021. Criteria: 2 CFR 200.329 Questioned Costs: $-0- Context: During the audit, it was identified that the University did not accurately report the total student grants and institutional expenses in the HEERF annual report. The University reviewed what was reported and corrected the report during the audit process. Cause: There was a transition in the key personnel completing the annual report, and part of the information used did not have the correct parameters for the calendar year 2021. Effect: The amounts reported on the annual report to the Department did not agree to the underlying records of the University or the quarterly reports prepared by the University. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University amend the 2021 annual report when the 2022 reporting cycle opens up the portal. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The transmission of information from the online platform included activity that did not meet the definition of academic activity resulting in students not having a correct calculation performed. Additionally, the new modular regulations were not correctly applied. Criteria: 34 CFR 668.22 Questioned Costs: $29,626 Context: Out of 31 students, 16 students who withdrew during the audit period tested had an incorrect return or lack of return. Four students did not have academic activity as defined in the regulation for their online course, and all funds should be returned for that term. Nine students, of which the majority was online modular students not a meeting withdrawal exemption, did not complete past 60% of the semester and should have had funds returned. Two students did not have academic activity as defined in the regulations for an online course and should have had Pell recalculated. One student had an incorrect calculation due to an incorrect scheduled break calculation. Cause: The programming in the online platform for meeting the definition of academic activity was not accurately set up for the 2021-2022 award year and inadvertently included any activity such as just logging in. If the student attended a second module without completing the first module, all days of the first module were counted as attended instead of the actual attended days. There was an oversight in a calendar set up for a scheduled break as well as using the date of determination as the withdrawal date rather than the last date of attendance. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs and incorrect returns. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the programming of the transmission of confirming attendance be specific to the regulations. We further recommend that federal aid is not disbursed to a student until academic activity in a class has been confirmed. We recommend the last date of academic activity be shared with the financial aid team systematically so calculations on all 0 credit students can be done timely. Should a student not begin attendance in an online class, we recommend the Pell be recalculated and returned immediately. We further recommend an additional layer of review on the calendar set up process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Appeals DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University missed requiring a formal satisfactory academic progress (SAP) appeals for one student. Criteria: 34 CFR 668.34(c) Questioned Costs: $7,676 Context: 1 student out of 12 tested was awarded federal aid but was ineligible due to not making SAP and did not have an approved appeal to reinstate eligibility. The University returned the federal aid during the audit process. Cause: There was an oversight of requiring an appeal for a student not making SAP. Effect: An ineligible student was awarded federal aid. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University ensure those students who were not meeting SAP have an approved appeal documented prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students selected for V4 verification inappropriately had the full V1 waiver applied. Criteria: 34 CFR 668.56 Questioned Costs: $10,374 Context: Out of 6 tested for the V4 or V5 flag of verification, 2 students did not have a statement of educational purpose on file. These students were corrected during the audit process. Cause: The waiver for verification only applied to the V1 portion of the flag but was inadvertently applied to the whole V4 flag. Effect: These students were not eligible for federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University obtain the signed statement of educational purpose, ID, and required transcripts for the V4 flag prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The transmission of information from the online platform included activity that did not meet the definition of academic activity resulting in students not having a correct calculation performed. Additionally, the new modular regulations were not correctly applied. Criteria: 34 CFR 668.22 Questioned Costs: $29,626 Context: Out of 31 students, 16 students who withdrew during the audit period tested had an incorrect return or lack of return. Four students did not have academic activity as defined in the regulation for their online course, and all funds should be returned for that term. Nine students, of which the majority was online modular students not a meeting withdrawal exemption, did not complete past 60% of the semester and should have had funds returned. Two students did not have academic activity as defined in the regulations for an online course and should have had Pell recalculated. One student had an incorrect calculation due to an incorrect scheduled break calculation. Cause: The programming in the online platform for meeting the definition of academic activity was not accurately set up for the 2021-2022 award year and inadvertently included any activity such as just logging in. If the student attended a second module without completing the first module, all days of the first module were counted as attended instead of the actual attended days. There was an oversight in a calendar set up for a scheduled break as well as using the date of determination as the withdrawal date rather than the last date of attendance. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs and incorrect returns. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the programming of the transmission of confirming attendance be specific to the regulations. We further recommend that federal aid is not disbursed to a student until academic activity in a class has been confirmed. We recommend the last date of academic activity be shared with the financial aid team systematically so calculations on all 0 credit students can be done timely. Should a student not begin attendance in an online class, we recommend the Pell be recalculated and returned immediately. We further recommend an additional layer of review on the calendar set up process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: 3 students out of 32 were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $-0- Context: Two students were student teaching in one semester and were not properly classified as traditional students during that semester, resulting in underawards of Pell of $2,018. Additionally, one student was incorrectly classified for the summer sessions and was underawarded Pell of $1,625. Cause: One financial aid counselor did not identify the transition in student type to apply the correct Pell formula. Effect: There was an incorrect amount of Pell paid to these three students. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend a process be used to adjust the Pell formula used to be in alignment with the type of student for that semester. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Appeals DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University missed requiring a formal satisfactory academic progress (SAP) appeals for one student. Criteria: 34 CFR 668.34(c) Questioned Costs: $7,676 Context: 1 student out of 12 tested was awarded federal aid but was ineligible due to not making SAP and did not have an approved appeal to reinstate eligibility. The University returned the federal aid during the audit process. Cause: There was an oversight of requiring an appeal for a student not making SAP. Effect: An ineligible student was awarded federal aid. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University ensure those students who were not meeting SAP have an approved appeal documented prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students selected for V4 verification inappropriately had the full V1 waiver applied. Criteria: 34 CFR 668.56 Questioned Costs: $10,374 Context: Out of 6 tested for the V4 or V5 flag of verification, 2 students did not have a statement of educational purpose on file. These students were corrected during the audit process. Cause: The waiver for verification only applied to the V1 portion of the flag but was inadvertently applied to the whole V4 flag. Effect: These students were not eligible for federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University obtain the signed statement of educational purpose, ID, and required transcripts for the V4 flag prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The transmission of information from the online platform included activity that did not meet the definition of academic activity resulting in students not having a correct calculation performed. Additionally, the new modular regulations were not correctly applied. Criteria: 34 CFR 668.22 Questioned Costs: $29,626 Context: Out of 31 students, 16 students who withdrew during the audit period tested had an incorrect return or lack of return. Four students did not have academic activity as defined in the regulation for their online course, and all funds should be returned for that term. Nine students, of which the majority was online modular students not a meeting withdrawal exemption, did not complete past 60% of the semester and should have had funds returned. Two students did not have academic activity as defined in the regulations for an online course and should have had Pell recalculated. One student had an incorrect calculation due to an incorrect scheduled break calculation. Cause: The programming in the online platform for meeting the definition of academic activity was not accurately set up for the 2021-2022 award year and inadvertently included any activity such as just logging in. If the student attended a second module without completing the first module, all days of the first module were counted as attended instead of the actual attended days. There was an oversight in a calendar set up for a scheduled break as well as using the date of determination as the withdrawal date rather than the last date of attendance. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs and incorrect returns. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the programming of the transmission of confirming attendance be specific to the regulations. We further recommend that federal aid is not disbursed to a student until academic activity in a class has been confirmed. We recommend the last date of academic activity be shared with the financial aid team systematically so calculations on all 0 credit students can be done timely. Should a student not begin attendance in an online class, we recommend the Pell be recalculated and returned immediately. We further recommend an additional layer of review on the calendar set up process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Appeals DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University missed requiring a formal satisfactory academic progress (SAP) appeals for one student. Criteria: 34 CFR 668.34(c) Questioned Costs: $7,676 Context: 1 student out of 12 tested was awarded federal aid but was ineligible due to not making SAP and did not have an approved appeal to reinstate eligibility. The University returned the federal aid during the audit process. Cause: There was an oversight of requiring an appeal for a student not making SAP. Effect: An ineligible student was awarded federal aid. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University ensure those students who were not meeting SAP have an approved appeal documented prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students selected for V4 verification inappropriately had the full V1 waiver applied. Criteria: 34 CFR 668.56 Questioned Costs: $10,374 Context: Out of 6 tested for the V4 or V5 flag of verification, 2 students did not have a statement of educational purpose on file. These students were corrected during the audit process. Cause: The waiver for verification only applied to the V1 portion of the flag but was inadvertently applied to the whole V4 flag. Effect: These students were not eligible for federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University obtain the signed statement of educational purpose, ID, and required transcripts for the V4 flag prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Appeals DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University missed requiring a formal satisfactory academic progress (SAP) appeals for one student. Criteria: 34 CFR 668.34(c) Questioned Costs: $7,676 Context: 1 student out of 12 tested was awarded federal aid but was ineligible due to not making SAP and did not have an approved appeal to reinstate eligibility. The University returned the federal aid during the audit process. Cause: There was an oversight of requiring an appeal for a student not making SAP. Effect: An ineligible student was awarded federal aid. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University ensure those students who were not meeting SAP have an approved appeal documented prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students selected for V4 verification inappropriately had the full V1 waiver applied. Criteria: 34 CFR 668.56 Questioned Costs: $10,374 Context: Out of 6 tested for the V4 or V5 flag of verification, 2 students did not have a statement of educational purpose on file. These students were corrected during the audit process. Cause: The waiver for verification only applied to the V1 portion of the flag but was inadvertently applied to the whole V4 flag. Effect: These students were not eligible for federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University obtain the signed statement of educational purpose, ID, and required transcripts for the V4 flag prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The transmission of information from the online platform included activity that did not meet the definition of academic activity resulting in students not having a correct calculation performed. Additionally, the new modular regulations were not correctly applied. Criteria: 34 CFR 668.22 Questioned Costs: $29,626 Context: Out of 31 students, 16 students who withdrew during the audit period tested had an incorrect return or lack of return. Four students did not have academic activity as defined in the regulation for their online course, and all funds should be returned for that term. Nine students, of which the majority was online modular students not a meeting withdrawal exemption, did not complete past 60% of the semester and should have had funds returned. Two students did not have academic activity as defined in the regulations for an online course and should have had Pell recalculated. One student had an incorrect calculation due to an incorrect scheduled break calculation. Cause: The programming in the online platform for meeting the definition of academic activity was not accurately set up for the 2021-2022 award year and inadvertently included any activity such as just logging in. If the student attended a second module without completing the first module, all days of the first module were counted as attended instead of the actual attended days. There was an oversight in a calendar set up for a scheduled break as well as using the date of determination as the withdrawal date rather than the last date of attendance. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs and incorrect returns. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the programming of the transmission of confirming attendance be specific to the regulations. We further recommend that federal aid is not disbursed to a student until academic activity in a class has been confirmed. We recommend the last date of academic activity be shared with the financial aid team systematically so calculations on all 0 credit students can be done timely. Should a student not begin attendance in an online class, we recommend the Pell be recalculated and returned immediately. We further recommend an additional layer of review on the calendar set up process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Appeals DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University missed requiring a formal satisfactory academic progress (SAP) appeals for one student. Criteria: 34 CFR 668.34(c) Questioned Costs: $7,676 Context: 1 student out of 12 tested was awarded federal aid but was ineligible due to not making SAP and did not have an approved appeal to reinstate eligibility. The University returned the federal aid during the audit process. Cause: There was an oversight of requiring an appeal for a student not making SAP. Effect: An ineligible student was awarded federal aid. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University ensure those students who were not meeting SAP have an approved appeal documented prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students selected for V4 verification inappropriately had the full V1 waiver applied. Criteria: 34 CFR 668.56 Questioned Costs: $10,374 Context: Out of 6 tested for the V4 or V5 flag of verification, 2 students did not have a statement of educational purpose on file. These students were corrected during the audit process. Cause: The waiver for verification only applied to the V1 portion of the flag but was inadvertently applied to the whole V4 flag. Effect: These students were not eligible for federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University obtain the signed statement of educational purpose, ID, and required transcripts for the V4 flag prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund Reporting Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.425E, 84.425F, 84.425L Federal Award Identification #: P425E202018, P425F202629, P425L200204 Condition: The University did not accurately report their student grant information and institutional expenditures on the HEERF Annual Report for the calendar year 2021. Criteria: 2 CFR 200.329 Questioned Costs: $-0- Context: During the audit, it was identified that the University did not accurately report the total student grants and institutional expenses in the HEERF annual report. The University reviewed what was reported and corrected the report during the audit process. Cause: There was a transition in the key personnel completing the annual report, and part of the information used did not have the correct parameters for the calendar year 2021. Effect: The amounts reported on the annual report to the Department did not agree to the underlying records of the University or the quarterly reports prepared by the University. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University amend the 2021 annual report when the 2022 reporting cycle opens up the portal. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund Reporting Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.425E, 84.425F, 84.425L Federal Award Identification #: P425E202018, P425F202629, P425L200204 Condition: The University did not accurately report their student grant information and institutional expenditures on the HEERF Annual Report for the calendar year 2021. Criteria: 2 CFR 200.329 Questioned Costs: $-0- Context: During the audit, it was identified that the University did not accurately report the total student grants and institutional expenses in the HEERF annual report. The University reviewed what was reported and corrected the report during the audit process. Cause: There was a transition in the key personnel completing the annual report, and part of the information used did not have the correct parameters for the calendar year 2021. Effect: The amounts reported on the annual report to the Department did not agree to the underlying records of the University or the quarterly reports prepared by the University. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University amend the 2021 annual report when the 2022 reporting cycle opens up the portal. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund Reporting Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.425E, 84.425F, 84.425L Federal Award Identification #: P425E202018, P425F202629, P425L200204 Condition: The University did not accurately report their student grant information and institutional expenditures on the HEERF Annual Report for the calendar year 2021. Criteria: 2 CFR 200.329 Questioned Costs: $-0- Context: During the audit, it was identified that the University did not accurately report the total student grants and institutional expenses in the HEERF annual report. The University reviewed what was reported and corrected the report during the audit process. Cause: There was a transition in the key personnel completing the annual report, and part of the information used did not have the correct parameters for the calendar year 2021. Effect: The amounts reported on the annual report to the Department did not agree to the underlying records of the University or the quarterly reports prepared by the University. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University amend the 2021 annual report when the 2022 reporting cycle opens up the portal. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.