Audit 83936

FY End
2022-06-30
Total Expended
$15.28M
Findings
8
Programs
14
Organization: Avila University (MO)
Year: 2022 Accepted: 2023-03-30
Auditor: Forvis LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
92912 2022-002 Significant Deficiency Yes N
92913 2022-003 Significant Deficiency - L
92914 2022-002 Significant Deficiency Yes N
92915 2022-003 Significant Deficiency - L
669354 2022-002 Significant Deficiency Yes N
669355 2022-003 Significant Deficiency - L
669356 2022-002 Significant Deficiency Yes N
669357 2022-003 Significant Deficiency - L

Contacts

Name Title Type
DGXAZ2M51UL3 Tonya Mourning Auditee
8165012487 Dustin Haywood Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on 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. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of the University under programs of the federal government for the year ended June 30, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows of the University.

Finding Details

Student Financial Assistance Cluster U.S. Department of Education CFDA Nos. 84.268, 84.063, Federal Direct Student Loans - Award Year 2022 Federal Pell Grant Program - Award Year 2022 Criteria or Specific Requirement ? Special Tests & Provisions: Enrollment Reporting Pell 34 CFR Section 690.83(b)(2); FDL, 34 CFR Section 685.309). Federal regulations state that enrollment information must be reported to the NSLDS website within 30 days of whenever attendance changes for students, unless a complete roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations or approved leave of absence Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition ? Enrollment information was not submitted within the required timeframe by the University. Questioned Costs ? None noted. Context ? Out of a population of 234 status changes, 40 changes were tested to ensure the University notified the NSLDS of student status changes in a timely manner and using accurate information. Nineteen errors were noted, including nine instances where notification was remitted late and ten instances where notification was reported but did not agree to the University's internal supporting documentation. The sample was not, and was not intended to be, a statistically valid sample. Effect ? Notification of student changes was not reported in a timely manner or was reported inaccurately. Cause ? Oversight by management. Identification as a Repeat Finding ? Yes, see prior year findings 2021-001, 2020-002 and 2019-003. Recommendation ? The University should implement monitoring policies and procedures to ensure that notifications are remitted timely and accurately. Views of Responsible Officials and Planned Corrective Actions ? Management has hired a new Director of Institutional Research and provided training and is aware of the federal regulations surrounding enrollment information that must be reported to the NSLDS. Given the complexity of the reporting, management has established additional policies and procedures to address the errors related to enrollment reporting to the NSLDS in a timely and accurate manner.
Student Financial Assistance Cluster U.S. Department of Education CFDA Nos. 84.268, 84.063, Federal Direct Student Loans - Award Year 2022 Federal Pell Grant Program - Award Year 2022 Criteria or Specific Requirement ? Reporting According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019, an institution must submit Pell and Direct Loan origination records and disbursement records to the Common Origination and Disbursement (COD) in a timely and accurate manner. Condition ? Federal Direct Loan and Pell disbursement dates per the University's billing system did not agree with the reportd dates per the Common Origination Disbursement (COD) records. Cost of attendance transaction numbers, and the Pell award amount did not agree between the students' file and COD records. Questioned Costs ? None noted. Context ? Out of a population of 931 students receiving Direct Loan awards and 541 students receiving Pell awards during the year, a sample of 40 students were selected for testing. Thirteen errors were noted. There were five instances in which the student's COA were not consistent with the COD for Pell awards. There were five instances in which the student's disbursement date was not consistent with the COD, and three instances in which the student's transaction code was not consistent with the COD for Direct Loan awards. The sample was not, and was not intended to be, a statistically valid sample. Effect ? The University did not report the accurate data (e.g., disbursement dates, amounts, and cost of attendance) to the COD. Cause ? Lack of reconciliation of student origination records to data provided to the COD. Identification as a Repeat Finding ? No Recommendation ? The University should review and update its processes and controls to ensure a formal reconciliation is provided for student origination records to the COD. Views of Responsible Officials and Planned Corrective Actions - Management has overhauled the underlying processes to include formal monthly reconciliations and additional levels of review. Further, the new process requires that Pell and Direct Loan origination and disbursement records are submitted to the COD by the end of next business day. The newly implemented reconciliation process validates disbursement dates, amounts and COA in the COD.
Student Financial Assistance Cluster U.S. Department of Education CFDA Nos. 84.268, 84.063, Federal Direct Student Loans - Award Year 2022 Federal Pell Grant Program - Award Year 2022 Criteria or Specific Requirement ? Special Tests & Provisions: Enrollment Reporting Pell 34 CFR Section 690.83(b)(2); FDL, 34 CFR Section 685.309). Federal regulations state that enrollment information must be reported to the NSLDS website within 30 days of whenever attendance changes for students, unless a complete roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations or approved leave of absence Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition ? Enrollment information was not submitted within the required timeframe by the University. Questioned Costs ? None noted. Context ? Out of a population of 234 status changes, 40 changes were tested to ensure the University notified the NSLDS of student status changes in a timely manner and using accurate information. Nineteen errors were noted, including nine instances where notification was remitted late and ten instances where notification was reported but did not agree to the University's internal supporting documentation. The sample was not, and was not intended to be, a statistically valid sample. Effect ? Notification of student changes was not reported in a timely manner or was reported inaccurately. Cause ? Oversight by management. Identification as a Repeat Finding ? Yes, see prior year findings 2021-001, 2020-002 and 2019-003. Recommendation ? The University should implement monitoring policies and procedures to ensure that notifications are remitted timely and accurately. Views of Responsible Officials and Planned Corrective Actions ? Management has hired a new Director of Institutional Research and provided training and is aware of the federal regulations surrounding enrollment information that must be reported to the NSLDS. Given the complexity of the reporting, management has established additional policies and procedures to address the errors related to enrollment reporting to the NSLDS in a timely and accurate manner.
Student Financial Assistance Cluster U.S. Department of Education CFDA Nos. 84.268, 84.063, Federal Direct Student Loans - Award Year 2022 Federal Pell Grant Program - Award Year 2022 Criteria or Specific Requirement ? Reporting According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019, an institution must submit Pell and Direct Loan origination records and disbursement records to the Common Origination and Disbursement (COD) in a timely and accurate manner. Condition ? Federal Direct Loan and Pell disbursement dates per the University's billing system did not agree with the reportd dates per the Common Origination Disbursement (COD) records. Cost of attendance transaction numbers, and the Pell award amount did not agree between the students' file and COD records. Questioned Costs ? None noted. Context ? Out of a population of 931 students receiving Direct Loan awards and 541 students receiving Pell awards during the year, a sample of 40 students were selected for testing. Thirteen errors were noted. There were five instances in which the student's COA were not consistent with the COD for Pell awards. There were five instances in which the student's disbursement date was not consistent with the COD, and three instances in which the student's transaction code was not consistent with the COD for Direct Loan awards. The sample was not, and was not intended to be, a statistically valid sample. Effect ? The University did not report the accurate data (e.g., disbursement dates, amounts, and cost of attendance) to the COD. Cause ? Lack of reconciliation of student origination records to data provided to the COD. Identification as a Repeat Finding ? No Recommendation ? The University should review and update its processes and controls to ensure a formal reconciliation is provided for student origination records to the COD. Views of Responsible Officials and Planned Corrective Actions - Management has overhauled the underlying processes to include formal monthly reconciliations and additional levels of review. Further, the new process requires that Pell and Direct Loan origination and disbursement records are submitted to the COD by the end of next business day. The newly implemented reconciliation process validates disbursement dates, amounts and COA in the COD.
Student Financial Assistance Cluster U.S. Department of Education CFDA Nos. 84.268, 84.063, Federal Direct Student Loans - Award Year 2022 Federal Pell Grant Program - Award Year 2022 Criteria or Specific Requirement ? Special Tests & Provisions: Enrollment Reporting Pell 34 CFR Section 690.83(b)(2); FDL, 34 CFR Section 685.309). Federal regulations state that enrollment information must be reported to the NSLDS website within 30 days of whenever attendance changes for students, unless a complete roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations or approved leave of absence Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition ? Enrollment information was not submitted within the required timeframe by the University. Questioned Costs ? None noted. Context ? Out of a population of 234 status changes, 40 changes were tested to ensure the University notified the NSLDS of student status changes in a timely manner and using accurate information. Nineteen errors were noted, including nine instances where notification was remitted late and ten instances where notification was reported but did not agree to the University's internal supporting documentation. The sample was not, and was not intended to be, a statistically valid sample. Effect ? Notification of student changes was not reported in a timely manner or was reported inaccurately. Cause ? Oversight by management. Identification as a Repeat Finding ? Yes, see prior year findings 2021-001, 2020-002 and 2019-003. Recommendation ? The University should implement monitoring policies and procedures to ensure that notifications are remitted timely and accurately. Views of Responsible Officials and Planned Corrective Actions ? Management has hired a new Director of Institutional Research and provided training and is aware of the federal regulations surrounding enrollment information that must be reported to the NSLDS. Given the complexity of the reporting, management has established additional policies and procedures to address the errors related to enrollment reporting to the NSLDS in a timely and accurate manner.
Student Financial Assistance Cluster U.S. Department of Education CFDA Nos. 84.268, 84.063, Federal Direct Student Loans - Award Year 2022 Federal Pell Grant Program - Award Year 2022 Criteria or Specific Requirement ? Reporting According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019, an institution must submit Pell and Direct Loan origination records and disbursement records to the Common Origination and Disbursement (COD) in a timely and accurate manner. Condition ? Federal Direct Loan and Pell disbursement dates per the University's billing system did not agree with the reportd dates per the Common Origination Disbursement (COD) records. Cost of attendance transaction numbers, and the Pell award amount did not agree between the students' file and COD records. Questioned Costs ? None noted. Context ? Out of a population of 931 students receiving Direct Loan awards and 541 students receiving Pell awards during the year, a sample of 40 students were selected for testing. Thirteen errors were noted. There were five instances in which the student's COA were not consistent with the COD for Pell awards. There were five instances in which the student's disbursement date was not consistent with the COD, and three instances in which the student's transaction code was not consistent with the COD for Direct Loan awards. The sample was not, and was not intended to be, a statistically valid sample. Effect ? The University did not report the accurate data (e.g., disbursement dates, amounts, and cost of attendance) to the COD. Cause ? Lack of reconciliation of student origination records to data provided to the COD. Identification as a Repeat Finding ? No Recommendation ? The University should review and update its processes and controls to ensure a formal reconciliation is provided for student origination records to the COD. Views of Responsible Officials and Planned Corrective Actions - Management has overhauled the underlying processes to include formal monthly reconciliations and additional levels of review. Further, the new process requires that Pell and Direct Loan origination and disbursement records are submitted to the COD by the end of next business day. The newly implemented reconciliation process validates disbursement dates, amounts and COA in the COD.
Student Financial Assistance Cluster U.S. Department of Education CFDA Nos. 84.268, 84.063, Federal Direct Student Loans - Award Year 2022 Federal Pell Grant Program - Award Year 2022 Criteria or Specific Requirement ? Special Tests & Provisions: Enrollment Reporting Pell 34 CFR Section 690.83(b)(2); FDL, 34 CFR Section 685.309). Federal regulations state that enrollment information must be reported to the NSLDS website within 30 days of whenever attendance changes for students, unless a complete roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations or approved leave of absence Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition ? Enrollment information was not submitted within the required timeframe by the University. Questioned Costs ? None noted. Context ? Out of a population of 234 status changes, 40 changes were tested to ensure the University notified the NSLDS of student status changes in a timely manner and using accurate information. Nineteen errors were noted, including nine instances where notification was remitted late and ten instances where notification was reported but did not agree to the University's internal supporting documentation. The sample was not, and was not intended to be, a statistically valid sample. Effect ? Notification of student changes was not reported in a timely manner or was reported inaccurately. Cause ? Oversight by management. Identification as a Repeat Finding ? Yes, see prior year findings 2021-001, 2020-002 and 2019-003. Recommendation ? The University should implement monitoring policies and procedures to ensure that notifications are remitted timely and accurately. Views of Responsible Officials and Planned Corrective Actions ? Management has hired a new Director of Institutional Research and provided training and is aware of the federal regulations surrounding enrollment information that must be reported to the NSLDS. Given the complexity of the reporting, management has established additional policies and procedures to address the errors related to enrollment reporting to the NSLDS in a timely and accurate manner.
Student Financial Assistance Cluster U.S. Department of Education CFDA Nos. 84.268, 84.063, Federal Direct Student Loans - Award Year 2022 Federal Pell Grant Program - Award Year 2022 Criteria or Specific Requirement ? Reporting According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019, an institution must submit Pell and Direct Loan origination records and disbursement records to the Common Origination and Disbursement (COD) in a timely and accurate manner. Condition ? Federal Direct Loan and Pell disbursement dates per the University's billing system did not agree with the reportd dates per the Common Origination Disbursement (COD) records. Cost of attendance transaction numbers, and the Pell award amount did not agree between the students' file and COD records. Questioned Costs ? None noted. Context ? Out of a population of 931 students receiving Direct Loan awards and 541 students receiving Pell awards during the year, a sample of 40 students were selected for testing. Thirteen errors were noted. There were five instances in which the student's COA were not consistent with the COD for Pell awards. There were five instances in which the student's disbursement date was not consistent with the COD, and three instances in which the student's transaction code was not consistent with the COD for Direct Loan awards. The sample was not, and was not intended to be, a statistically valid sample. Effect ? The University did not report the accurate data (e.g., disbursement dates, amounts, and cost of attendance) to the COD. Cause ? Lack of reconciliation of student origination records to data provided to the COD. Identification as a Repeat Finding ? No Recommendation ? The University should review and update its processes and controls to ensure a formal reconciliation is provided for student origination records to the COD. Views of Responsible Officials and Planned Corrective Actions - Management has overhauled the underlying processes to include formal monthly reconciliations and additional levels of review. Further, the new process requires that Pell and Direct Loan origination and disbursement records are submitted to the COD by the end of next business day. The newly implemented reconciliation process validates disbursement dates, amounts and COA in the COD.