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Finding #2023-002 – Internal Controls over Federal Grant Reporting Description of Finding: The City received a significant amount of grant funding during the year ending June 30, 2023, including federal funds that were received in advance. Material audit adjustments were required to increase grant ...
Finding #2023-002 – Internal Controls over Federal Grant Reporting Description of Finding: The City received a significant amount of grant funding during the year ending June 30, 2023, including federal funds that were received in advance. Material audit adjustments were required to increase grant receivables, record an advance from grantors, and increase grant revenue. The grant activity was primarily recorded on the cash basis in the general ledger, which is not consistent with generally accepted accounting principles. Statement of Concurrence or Nonconcurrence: Concurrence Planned Correction Action: A new Finance Director was hired in March 2024 to replace the outgoing employee. A new City Treasurer was hired in June 2024 to replace the outgoing employee. The Finance Director has met with Department Heads and the Treasurer to review grants. We are balancing the current grants the best we can with the information provided. Starting with new grants and projects we are assigning project numbers to isolate information for balancing purposes. Training on the BS&A software, with specific attention to grants and projects, has been scheduled for December 2024. We are also creating receivable invoices when requesting grant reimbursement to track the funds received. We are setting up a schedule for grant review quarterly. A consultant specializing in State and Federal Grant reporting has been engaged to assist the Finance Department in addressing any weakness in grant accounting identified by the auditor. We will be preparing a grant policy for the council to review and adopt in the coming months. Anticipated Completion Date: 06/30/2025
The County Clerk and County Treasurer watched the live informational Zoom meeting to learn how to fill out the SLFRF Project and Expenditures Report correctly. For entities who received less than $10 million in SLFRF, the entity was allowed to report the total amount as a loss in revenue. The slide ...
The County Clerk and County Treasurer watched the live informational Zoom meeting to learn how to fill out the SLFRF Project and Expenditures Report correctly. For entities who received less than $10 million in SLFRF, the entity was allowed to report the total amount as a loss in revenue. The slide show was difficult to understand and follow, but we mistakenly thought we were supposed to put $0 on that part of the report. After the auditors discussed this error with me, I went to the reporting website to correct the error; however, the website would not allow changes to the report after a certain period of time. In the future we will report the difference in total expenditures between the two reporting periods. McDonald County is of the opinion that the U.S. Department of Treasury has changed reporting requirements, information, and acceptable expenditures so many times, they have made the reporting requirements difficult to understand or follow. We will do our best to not have an error in the next report.
Views of Responsible Officials and Planned Corrective Actions: USTTI will prepare FFR's based on actual expenditures for each quarter. USTTI will make best efforts to ensure transactions are reflected in the general ledger before preparation of the FFR's. USTTI will also adjust the work flow of prep...
Views of Responsible Officials and Planned Corrective Actions: USTTI will prepare FFR's based on actual expenditures for each quarter. USTTI will make best efforts to ensure transactions are reflected in the general ledger before preparation of the FFR's. USTTI will also adjust the work flow of preparation and approval of the FFR's.
Views of Responsible Officials and Planned Corrective Actions: USTTI will prepare its SEFA on a quarterly basis, and we will reconcile the expenses reported on the SEFA with general ledger amounts. We will also review the chart of accounts coding to be sure all eligible expenses are clearly identifi...
Views of Responsible Officials and Planned Corrective Actions: USTTI will prepare its SEFA on a quarterly basis, and we will reconcile the expenses reported on the SEFA with general ledger amounts. We will also review the chart of accounts coding to be sure all eligible expenses are clearly identified.
The federal agencies require that all entities expending $750,000 or more under department awards to have an audit of its federal awards performed and completed within nine months of the company’s fiscal year-end. Management of Young Women’s Christian Association of Newburyport, d/b/a YWCA Greater N...
The federal agencies require that all entities expending $750,000 or more under department awards to have an audit of its federal awards performed and completed within nine months of the company’s fiscal year-end. Management of Young Women’s Christian Association of Newburyport, d/b/a YWCA Greater Newburyport, its Affiliate and Subsidiaries is aware of the financial audit deadline and Federal award expenditure threshold and is in the process of instituting safeguards to ensure future audits are timely file. It is the intention of the company to file the 2024 audit by September 30, 2025. John Feehan, Executive Director, is responsible for implementing this corrective action plan.
Pursuant to Standards for Internal Control in the Federal Government, Principle 16-Performing Monitoring Activities, management should monitor its internal control system through ongoing monitoring and separate evaluations including but not limited to comparisons, reconciliations and other routine a...
Pursuant to Standards for Internal Control in the Federal Government, Principle 16-Performing Monitoring Activities, management should monitor its internal control system through ongoing monitoring and separate evaluations including but not limited to comparisons, reconciliations and other routine actions. Young Women’s Christian Association of Newburyport, d/b/a YWCA Greater Newburyport, its Affiliate and Subsidiaries’ is in the process of developing internal control procedures over reconciliation and recognition of Federal funds. The person responsible for this periodic reconciliation of Federal funds will indicate their review keeping documentation of their analysis on file with the accounting office. John Feehan, Executive Director, is responsible for implementing this corrective action plan.
2023-003: Deficiency in Internal Controls and Compliance Finding -COVID-19 – Education Stabilization Fund – ALN 84.425: Two final financial reports due during the prior fiscal years were not submitted. (Questioned Costs: None) The Town of Clinton/School Department will follow grants closeout proced...
2023-003: Deficiency in Internal Controls and Compliance Finding -COVID-19 – Education Stabilization Fund – ALN 84.425: Two final financial reports due during the prior fiscal years were not submitted. (Questioned Costs: None) The Town of Clinton/School Department will follow grants closeout procedures, consequently, the district will monitor closely all grants spending throughout each grant cycle. For both state-administered and direct grants, regardless of the period of availability, the District must liquidate all obligations incurred under the award Reports not later than 90 days after the end of the funding period unless an extension is authorized. These procedures have been updated in the Financial Procedures Manual (pages 226-230 under Section G— Timely Obligation of Funds)
Condition: The District did not comply with the requirements of filing quarterly and period reports by the due dates set by ISBE. A total of 6 reports were filed late. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting...
Condition: The District did not comply with the requirements of filing quarterly and period reports by the due dates set by ISBE. A total of 6 reports were filed late. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion: 6/30/2024. Name of Contact Person: Dr. Maureen M. White, Superintendent. Management Response: Management will work together with staff to verify that reporting deadlines are met moving forward.
Condition: The District did not comply with the requirements of filing quarterly and period reports by the due dates set by ISBE. A total of 12 reports were filed late. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporti...
Condition: The District did not comply with the requirements of filing quarterly and period reports by the due dates set by ISBE. A total of 12 reports were filed late. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion: 6/30/2024. Name of Contact Person: Dr. Maureen M. White, Superintendent. Management Response: Management will work together with staff to verify that reporting deadlines are met moving forward.
FA 2023-002 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Educatio...
FA 2023-002 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) Questioned Costs: None Identified Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Education Stabilization Fund. Corrective Action Plans: The Finance Department will implement a revision process to work with the technology departments Media Specialist who conduct inventory on an annual basis. We will implement a quarterly meeting to identify any changes in equipment and real property. When funds are identified as equipment and real property for federal grant funds. We adhere to provisions included in the Uniform Guidance, Section 200.313(d)(1). The listing must include the following information. A description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate deposal data for each piece of equipment. Estimated Completion Date: April 30, 2025 Contact Person: Dr. Jute Wilson Telephone: 770-358-5891 Email: Jute.Wilson@lamar.k12.ga.us
Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. The corrective action plan to address this deficiency includes the following actions: (1) Monitor all expenses to ensure Vouchers are based on accrual basis, not cash basis, at year end (...
Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. The corrective action plan to address this deficiency includes the following actions: (1) Monitor all expenses to ensure Vouchers are based on accrual basis, not cash basis, at year end (2) Reconcile expenses submitted on vouchers monthly beginning November 1, 2024 Name(s) of the contact person(s) responsible for corrective action: Mary Ann Mahon Huels, President and CEO, Hector Perez, Senior Vice President and Mary Zaleski, Consultant Planned completion date for corrective action plan: The corrective action plan detailed above is being implemented today, October 21, 2024
2023-002 Twenty-First Century Community Learning Centers -Assistance Li st ing No. 84.287 Significant Deficiency in Internal Control Over Compliance -Appropriate Monitoring of Levels of Federal Funding Recommendation: The Auditor recommends BGCH should implement policies and procedures to periodical...
2023-002 Twenty-First Century Community Learning Centers -Assistance Li st ing No. 84.287 Significant Deficiency in Internal Control Over Compliance -Appropriate Monitoring of Levels of Federal Funding Recommendation: The Auditor recommends BGCH should implement policies and procedures to periodically monitor federal funding and expenditure levels throughout the year to ensure a level of awareness regarding whether an audit under the Uniform Guidance may be applicable for the current year. In addition, the Organization should prepare a schedule of federal expenditures (SEFA) as part of its year-end closing process, which reconciles to the general ledger. The SEFA and data used to prepare the SEFA should be reviewed by a separate individual within the Organization with knowledge of the related reporting requirements, as outlined in the Uniform Guidance, to ensure its accuracy and completeness. The schedule should be used to determine whether an audit in accordance with the provisions of the Uniform Guidance is required so that an auditor may be engaged to perform a timely audit. Planned Corrective Action: We agree with the recommendation and plan to have the corrective action implemented by December 31, 2024. Boys & Girls Club of Huntington Finance Board Subcommittee discusses this item throughout the fiscal year and is in the Board minutes, but has not put a written policy in place. A policy will be created by the Finance Board Subcommittee at the October meeting, presented to the full Board of Directors at the November Board meeting and voted on at the December 2024 Board meeting.
Finding 507933 (2023-001)
Significant Deficiency 2023
The City will have each department that maintains comsumable materials and small equipments with less than one year shelf-life complete a physical inventory county of items on hand at the end of each fiscal year. The vaule of the inventory will be adjusted to reflect the inventory at the lower of c...
The City will have each department that maintains comsumable materials and small equipments with less than one year shelf-life complete a physical inventory county of items on hand at the end of each fiscal year. The vaule of the inventory will be adjusted to reflect the inventory at the lower of cost or market based of the physcial count.
7. Management Response: Centennial BOCES will begin monitoring and collecting monthly time and effort for all listed employees of subgrantees. Centennial BOCES will continue to collect time and effort documentation within Centennial BOCES staff. The BOCES will treat subgrantee employees as if they w...
7. Management Response: Centennial BOCES will begin monitoring and collecting monthly time and effort for all listed employees of subgrantees. Centennial BOCES will continue to collect time and effort documentation within Centennial BOCES staff. The BOCES will treat subgrantee employees as if they were Centennial BOCES employees regarding collection of time and effort reports following appropriate policies and procedures. At fiscal year-end a reconciliation of all documents required, including time and effort documentation, will be completed.
Finding 2023-002 – Reporting (Material Weakness) Repeat Finding – See Finding 2022-001 US Department of the Treasury – COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The County’s submitted reports for ARPA do not materially agree to the expenditures reporte...
Finding 2023-002 – Reporting (Material Weakness) Repeat Finding – See Finding 2022-001 US Department of the Treasury – COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The County’s submitted reports for ARPA do not materially agree to the expenditures reported in the trial balance. Criteria: In accordance with the federal compliance requirements for ARPA, current reporting period expenditures and cumulative expenditures must be entered for each project. Cause: There was not a review and a reconciliation of the amounts being submitted on the reports to the amounts recorded in the trial balance. Effect: The County is not in compliance with reporting requirements, and failure to comply with grant award requirements could jeopardize future funding and does not allow the funder to adequately oversee the use of their funding. Recommendation: We recommend that the County continue its efforts in evaluating its procedures to ensure that all required reports are accurately submitted. Management Response: External auditors and management discussed ongoing issues with the policies written about reporting and the limits of the reporting system provided by the federal government. To further complicate matters as the federal COVID money is spent and reporting is now coming to an end the federal government is providing less support for the existing reporting system. However, we will continue to work assure timely and accurate reporting of all ARPA funds as required.
The Town has put in place a process for more accurate year end closing and financial statement preparation.
The Town has put in place a process for more accurate year end closing and financial statement preparation.
Management will ensure that all grant reports submitted to federal agencies are reviewed and approved by the Tazewell County manager overseeing the grant prior to submission. The County will review and approve all necessary supporting documents including certified payrolls to verify compliance with ...
Management will ensure that all grant reports submitted to federal agencies are reviewed and approved by the Tazewell County manager overseeing the grant prior to submission. The County will review and approve all necessary supporting documents including certified payrolls to verify compliance with federal reporting requirements and guidelines. When outside consultants are engaged to aid in grant administration, the appropriate Tazewell County manager will be responsible for reviewing and approving all required reporting and supporting documentation prepared on the County’s behalf.
Moving forward, the District will ensure that all items reported to various agencies, including the California Department of Education, are supported and are retained to external review.
Moving forward, the District will ensure that all items reported to various agencies, including the California Department of Education, are supported and are retained to external review.
Finding 507058 (2023-014)
Significant Deficiency 2023
Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR ...
Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025 Anticipated Completion Date: December 31, 2024
View Audit 328267 Questioned Costs: $1
Finding 507052 (2023-013)
Significant Deficiency 2023
Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporti...
Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024. Anticipated Completion Date: December 31, 2024
Finding 506686 (2023-012)
Significant Deficiency 2023
Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts and Warren Petty, Chief Human Resource Officer Corrective Action: The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system...
Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts and Warren Petty, Chief Human Resource Officer Corrective Action: The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding. A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary. Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions. Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process. Anticipated Completion Date: June 30, 2025
Finding 505595 (2023-007)
Significant Deficiency 2023
Name of Responsible Individual: Edward Harper, Senior Associate Director of Financial Aid Corrective Action: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Ai...
Name of Responsible Individual: Edward Harper, Senior Associate Director of Financial Aid Corrective Action: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024. Anticipated Completion Date: The policy and procedure for V4 verification intake was updated in February 2024 and the training of Financial Aid Counselors occurred in February and March 2024. There will be annual training of Financial Aid Counselors on following appropriate verification procedures as needed. The Associate Director for Compliance performed a review of V4 verification documents processed by Financial Aid Counselors in March 2024 and June 2024. All V4 verification documents received after the training followed the updated policy and procedure. Another review of V4 verification will be completed in September 2024 and any additional training required will be scheduled.
Finding 505588 (2023-006)
Significant Deficiency 2023
Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Roderick Johnson, Assistant Director for Compliance, Robert Muhammad, Executive Director of Financial Aid and Robin Whitfield, Associate VP for Finance & Bursar Corrective Action: It was discovered in December 2021 t...
Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Roderick Johnson, Assistant Director for Compliance, Robert Muhammad, Executive Director of Financial Aid and Robin Whitfield, Associate VP for Finance & Bursar Corrective Action: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Anticipated Completion Date: December 2024 is the anticipated date by which Howard would expect the comparison process to be completed. Howard has been in contact with ECSI and the comparison process is still ongoing.
Finding 505587 (2023-005)
Significant Deficiency 2023
Name of Responsible Individual: Konya White, Director of Enrollment Systems Associate Director for Compliance, Ben Carmichael, Associate Director for Compliance, and Roderick Johnson, Assistant Director for Compliance Corrective Action: This student’s Pell disbursement was not reported within 15 da...
Name of Responsible Individual: Konya White, Director of Enrollment Systems Associate Director for Compliance, Ben Carmichael, Associate Director for Compliance, and Roderick Johnson, Assistant Director for Compliance Corrective Action: This student’s Pell disbursement was not reported within 15 days of disbursement due to the COD (Common Origination Disbursement) system rejecting the student’s disbursement. These Pell rejects are worked through the reconciliation process and this exception was not worked in a timely manner, resulting in COD accepting the disbursement past the 15-day deadline. The Howard University employee who was completing reconciliation of Title IV funds, as well as responsible for working through any Pell rejected disbursements is no longer employed at Howard. The Assistant Director for Compliance works in the Office of Financial Aid and responsible for completing reconciliation and working any Pell rejected disbursements. The Associate Director for Compliance in Enrollment Management reviews reconciliations and ensures any rejected disbursements are resolved within the 15-day timeframe. Anticipated Completion Date: This finding was mitigated in May 2023. The responsibility of Title IV reconciliation was performed and worked by two consultants who had experience with Title IV reconciliation. The Assistant Director for Compliance hired in January 2024 has experience with Title IV reconciliation and was trained by the two consultants on Howard procedures for Title IV reconciliation and working rejected disbursements. The responsibility for Title IV reconciliation now lies entirely within the Office of Financial Aid.
Finding 505583 (2023-003)
Significant Deficiency 2023
Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Konya White, Director of Enrollment Systems and LaTrice Byam, Executive Director of Academic Planning and Curriculum Corrective Action: The Enrollment Reporting process is supervised by the University Registrar and ...
Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Konya White, Director of Enrollment Systems and LaTrice Byam, Executive Director of Academic Planning and Curriculum Corrective Action: The Enrollment Reporting process is supervised by the University Registrar and is responsible for providing enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (“NSC”), who then submits the report to NSLDS student’s enrollment status. The University is committed to ensure sufficient training and support to the Office of the Registrar to keep the institution in compliance. While the expectation is the University will hire an experienced University Registrar and Associate Director Registrar for compliance, continued training opportunities will be made available through National Student Clearinghouse and NASFAA (National Association of Student Financial Aid Administrators). The reported data is for students who are ¾ time during a semester, “3Q,” was discovered through testing of enrollment reporting samples to not be set up correctly in Banner. This has resulted in students who are taking between 9-11 credits being reported as “H” for half-time instead of “3Q” for three-quarter time. The newest University Registrar set up the “3Q” status correctly in Banner in January 2024 and testing of enrollment reporting samples show the 3Q status is accurate. The students in the program and campus-level findings should now be accurately reported as “3Q.” After speaking with the Executive Director of Academic Planning and Curriculum, the CIP codes for the program identified as findings had not been updated when all CIP codes were updated in 2020. She also confirmed the length of the program was incorrectly published on the site for these programs. Howard has moved to Workday Student as the University’s Enterprise Resource Planning system and the accurate CIP codes and program lengths were confirmed. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday. The University Registrar was not aware the FSA Audit testing exempt range of 07-19-2022 through 02-28-2024 required students who had an enrollment change during that period to be updated. This audit exemption range was abnormal, and the University hired a new Registrar during this time period, which resulted in there being no knowledge transfer the enrollment changes had not been updated. Graduation files are now being sent monthly to the National Student Clearinghouse to avoid students not being picked up for graduation as they are cleared. Anticipated Completion Date: The correction to the “3Q” status took place in January 2024 and testing has shown this issue to be resolved. Additional testing will occur in the new ERP Workday to ensure incorrect reporting of students who are ¾ time does not occur. Enrollment reporting samples will be pulled approximately 2-3 weeks after the first Fall 2024 enrollment file is sent to National Student Clearinghouse.
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