Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: Yes, see finding 2023-002. Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: Yes, see finding 2023-002. Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: Yes, see finding 2023-002. Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Views of responsible officials: There is no disagreement with the audit finding.
Condition: During our audit, we noted that management did not implement internal controls over participant eligibility. It was noted while testing key control over the sampled population of participants for the major program tested. The sampled population was determined to be statistically valid. Criteria: The Organization must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in the Organization's internal controls. Cause: Management did not design and implement internal controls to review participant eligibility. Effect: The absence of controls over participant eligibility incurred lead to an increase risk of errors and noncompliance in the financial statements which could misrepresent the Organization's financial statements. Recommendation: We recommend the organization implements a process to ensure that individuals income eligibility is being verified and that the food staff working for the organization understand their responsibilities. Views of Responsible Officials: Management agrees with the finding.
Condition: During our audit, we noted that management did not implement internal controls over participant eligibility. It was noted while testing key control over the sampled population of participants for the major program tested. The sampled population was determined to be statistically valid. Criteria: The Organization must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award per CFR § 200.303. These requirements detail the information that must be included in the Organization's internal controls. Cause: Management did not design and implement internal controls to review participant eligibility. Effect: The absence of controls over participant eligibility incurred lead to an increase risk of errors and noncompliance in the financial statements which could misrepresent the Organization's financial statements. Recommendation: We recommend the organization implements a process to ensure that individuals income eligibility is being verified and that the food staff working for the organization understand their responsibilities. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Federal Award Identification Number and Year: N/A; 2023-2024 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: Federal regulations and related guidance governing Title IV student aid programs requires institutions to accurately and timely report enrollment information to the National Student Loan Data System (NSLDS). Institutions must ensure that the reported data is complete and accurate, reflecting the student's actual enrollment status at the campus and program levels, including full-time, half-time, graduated, withdrawn, or any other status changes. This requirement helps maintain the integrity of the federal student aid programs and ensures that students' loan repayment statuses are correctly managed (NSLDS Enrollment Reporting Guide, November 2022, Chapter 2). Changes in enrollment status must be reported within 60 days of determining the student's status has changed. In addition, institutions must certify enrollment status on an ongoing basis, at least every 60 days (NSLDS Enrollment Reporting Guide, November 2022, Chapter 5).The data reported, including the effective date of enrollment status, must match the institution's internal records and reflect the student's current enrollment status (NSLDS Enrollment Reporting Guide, November 2022, Chapter 4). Finally, if the institution uses a third-party servicer for reporting, it must ensure that the servicer complies with all federal reporting requirements (NSLDS Enrollment Reporting Guide, November 2022, Chapter 3, Section 3.3). According to 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our audit of the District's enrollment reporting to NSLDS, for 26 (65%) of 40 students tested, the District did not accurately and timely report enrollment status changes to NSLDS. Specifically: • 14 of these students did not have the correct enrollment status reported; • 23 of these students did not have the enrollment status effective date reported accurately; • 18 of these students did not have their enrollment status change reported within 60 days of the date the District determined the change in status; • 17 of these students did not have their enrollment status verified on an ongoing basis per the required 60-day timeframe during the fiscal year. Questioned costs: None Context: The District uses the services of the National Student Clearinghouse (NSC) to report status changes to NSLDS. Under this arrangement, the District reports all students enrolled and their status to NSC. NSC then identifies any changes in status and reports those changes to NSLDS when required. Although the District uses the services of NSC, the District still has the primary responsibility to report any changes in student enrollment status accurately and in a timely manner. Cause: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Effect: Failure to comply with these reporting requirements can result in administrative actions, including fines and penalties, and can affect the institution's eligibility to participate in federal student aid programs. Non-compliance may also lead to inaccurate loan repayment statuses for students, potentially causing financial hardship. Repeat finding: No Recommendation: We recommend that the District enhance its oversight and monitoring of the third-party service provider responsible for reporting enrollment status changes to NSLDS. Views of responsible officials: The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehensive process to resubmit corrected enrollment files to the NSC, covering Spring 2023, Summer 2023, and Fall 2023. In collaboration with NSC, we followed their established process to rectify the error, which required reloading each submission one at a time in succession from the original submission with the error. This process caused delays in our subsequent submissions until the corrections were fully completed. To prevent recurrence, we have implemented enhanced checks and controls prior to each submission to review the file and file size to ensure the correct number of students are submitted to NSC. Additionally, all submissions post-Spring 2023 have been reviewed, and we have confirmed that this was an isolated incident.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Federal Award Identification Number and Year: N/A; 2023-2024 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: Federal regulations and related guidance governing Title IV student aid programs requires institutions to accurately and timely report enrollment information to the National Student Loan Data System (NSLDS). Institutions must ensure that the reported data is complete and accurate, reflecting the student's actual enrollment status at the campus and program levels, including full-time, half-time, graduated, withdrawn, or any other status changes. This requirement helps maintain the integrity of the federal student aid programs and ensures that students' loan repayment statuses are correctly managed (NSLDS Enrollment Reporting Guide, November 2022, Chapter 2). Changes in enrollment status must be reported within 60 days of determining the student's status has changed. In addition, institutions must certify enrollment status on an ongoing basis, at least every 60 days (NSLDS Enrollment Reporting Guide, November 2022, Chapter 5).The data reported, including the effective date of enrollment status, must match the institution's internal records and reflect the student's current enrollment status (NSLDS Enrollment Reporting Guide, November 2022, Chapter 4). Finally, if the institution uses a third-party servicer for reporting, it must ensure that the servicer complies with all federal reporting requirements (NSLDS Enrollment Reporting Guide, November 2022, Chapter 3, Section 3.3). According to 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our audit of the District's enrollment reporting to NSLDS, for 26 (65%) of 40 students tested, the District did not accurately and timely report enrollment status changes to NSLDS. Specifically: • 14 of these students did not have the correct enrollment status reported; • 23 of these students did not have the enrollment status effective date reported accurately; • 18 of these students did not have their enrollment status change reported within 60 days of the date the District determined the change in status; • 17 of these students did not have their enrollment status verified on an ongoing basis per the required 60-day timeframe during the fiscal year. Questioned costs: None Context: The District uses the services of the National Student Clearinghouse (NSC) to report status changes to NSLDS. Under this arrangement, the District reports all students enrolled and their status to NSC. NSC then identifies any changes in status and reports those changes to NSLDS when required. Although the District uses the services of NSC, the District still has the primary responsibility to report any changes in student enrollment status accurately and in a timely manner. Cause: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Effect: Failure to comply with these reporting requirements can result in administrative actions, including fines and penalties, and can affect the institution's eligibility to participate in federal student aid programs. Non-compliance may also lead to inaccurate loan repayment statuses for students, potentially causing financial hardship. Repeat finding: No Recommendation: We recommend that the District enhance its oversight and monitoring of the third-party service provider responsible for reporting enrollment status changes to NSLDS. Views of responsible officials: The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehensive process to resubmit corrected enrollment files to the NSC, covering Spring 2023, Summer 2023, and Fall 2023. In collaboration with NSC, we followed their established process to rectify the error, which required reloading each submission one at a time in succession from the original submission with the error. This process caused delays in our subsequent submissions until the corrections were fully completed. To prevent recurrence, we have implemented enhanced checks and controls prior to each submission to review the file and file size to ensure the correct number of students are submitted to NSC. Additionally, all submissions post-Spring 2023 have been reviewed, and we have confirmed that this was an isolated incident.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Federal Award Identification Number and Year: N/A; 2023-2024 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: Federal regulations and related guidance governing Title IV student aid programs requires institutions to accurately and timely report enrollment information to the National Student Loan Data System (NSLDS). Institutions must ensure that the reported data is complete and accurate, reflecting the student's actual enrollment status at the campus and program levels, including full-time, half-time, graduated, withdrawn, or any other status changes. This requirement helps maintain the integrity of the federal student aid programs and ensures that students' loan repayment statuses are correctly managed (NSLDS Enrollment Reporting Guide, November 2022, Chapter 2). Changes in enrollment status must be reported within 60 days of determining the student's status has changed. In addition, institutions must certify enrollment status on an ongoing basis, at least every 60 days (NSLDS Enrollment Reporting Guide, November 2022, Chapter 5).The data reported, including the effective date of enrollment status, must match the institution's internal records and reflect the student's current enrollment status (NSLDS Enrollment Reporting Guide, November 2022, Chapter 4). Finally, if the institution uses a third-party servicer for reporting, it must ensure that the servicer complies with all federal reporting requirements (NSLDS Enrollment Reporting Guide, November 2022, Chapter 3, Section 3.3). According to 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our audit of the District's enrollment reporting to NSLDS, for 26 (65%) of 40 students tested, the District did not accurately and timely report enrollment status changes to NSLDS. Specifically: • 14 of these students did not have the correct enrollment status reported; • 23 of these students did not have the enrollment status effective date reported accurately; • 18 of these students did not have their enrollment status change reported within 60 days of the date the District determined the change in status; • 17 of these students did not have their enrollment status verified on an ongoing basis per the required 60-day timeframe during the fiscal year. Questioned costs: None Context: The District uses the services of the National Student Clearinghouse (NSC) to report status changes to NSLDS. Under this arrangement, the District reports all students enrolled and their status to NSC. NSC then identifies any changes in status and reports those changes to NSLDS when required. Although the District uses the services of NSC, the District still has the primary responsibility to report any changes in student enrollment status accurately and in a timely manner. Cause: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Effect: Failure to comply with these reporting requirements can result in administrative actions, including fines and penalties, and can affect the institution's eligibility to participate in federal student aid programs. Non-compliance may also lead to inaccurate loan repayment statuses for students, potentially causing financial hardship. Repeat finding: No Recommendation: We recommend that the District enhance its oversight and monitoring of the third-party service provider responsible for reporting enrollment status changes to NSLDS. Views of responsible officials: The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehensive process to resubmit corrected enrollment files to the NSC, covering Spring 2023, Summer 2023, and Fall 2023. In collaboration with NSC, we followed their established process to rectify the error, which required reloading each submission one at a time in succession from the original submission with the error. This process caused delays in our subsequent submissions until the corrections were fully completed. To prevent recurrence, we have implemented enhanced checks and controls prior to each submission to review the file and file size to ensure the correct number of students are submitted to NSC. Additionally, all submissions post-Spring 2023 have been reviewed, and we have confirmed that this was an isolated incident.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Federal Award Identification Number and Year: N/A; 2023-2024 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: Federal regulations and related guidance governing Title IV student aid programs requires institutions to accurately and timely report enrollment information to the National Student Loan Data System (NSLDS). Institutions must ensure that the reported data is complete and accurate, reflecting the student's actual enrollment status at the campus and program levels, including full-time, half-time, graduated, withdrawn, or any other status changes. This requirement helps maintain the integrity of the federal student aid programs and ensures that students' loan repayment statuses are correctly managed (NSLDS Enrollment Reporting Guide, November 2022, Chapter 2). Changes in enrollment status must be reported within 60 days of determining the student's status has changed. In addition, institutions must certify enrollment status on an ongoing basis, at least every 60 days (NSLDS Enrollment Reporting Guide, November 2022, Chapter 5).The data reported, including the effective date of enrollment status, must match the institution's internal records and reflect the student's current enrollment status (NSLDS Enrollment Reporting Guide, November 2022, Chapter 4). Finally, if the institution uses a third-party servicer for reporting, it must ensure that the servicer complies with all federal reporting requirements (NSLDS Enrollment Reporting Guide, November 2022, Chapter 3, Section 3.3). According to 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our audit of the District's enrollment reporting to NSLDS, for 26 (65%) of 40 students tested, the District did not accurately and timely report enrollment status changes to NSLDS. Specifically: • 14 of these students did not have the correct enrollment status reported; • 23 of these students did not have the enrollment status effective date reported accurately; • 18 of these students did not have their enrollment status change reported within 60 days of the date the District determined the change in status; • 17 of these students did not have their enrollment status verified on an ongoing basis per the required 60-day timeframe during the fiscal year. Questioned costs: None Context: The District uses the services of the National Student Clearinghouse (NSC) to report status changes to NSLDS. Under this arrangement, the District reports all students enrolled and their status to NSC. NSC then identifies any changes in status and reports those changes to NSLDS when required. Although the District uses the services of NSC, the District still has the primary responsibility to report any changes in student enrollment status accurately and in a timely manner. Cause: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Effect: Failure to comply with these reporting requirements can result in administrative actions, including fines and penalties, and can affect the institution's eligibility to participate in federal student aid programs. Non-compliance may also lead to inaccurate loan repayment statuses for students, potentially causing financial hardship. Repeat finding: No Recommendation: We recommend that the District enhance its oversight and monitoring of the third-party service provider responsible for reporting enrollment status changes to NSLDS. Views of responsible officials: The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehensive process to resubmit corrected enrollment files to the NSC, covering Spring 2023, Summer 2023, and Fall 2023. In collaboration with NSC, we followed their established process to rectify the error, which required reloading each submission one at a time in succession from the original submission with the error. This process caused delays in our subsequent submissions until the corrections were fully completed. To prevent recurrence, we have implemented enhanced checks and controls prior to each submission to review the file and file size to ensure the correct number of students are submitted to NSC. Additionally, all submissions post-Spring 2023 have been reviewed, and we have confirmed that this was an isolated incident.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 (Federal Pell Grant Program), 84.007 (Supplemental Educational Opportunity Grant), 84.033 (College Work Study), 84.268 (Federal Direct Student Loans Program), Federal Award Identification Number and Year: N/A; 2023-2024 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: According to 34 CFR 668.55, institutions are required to verify certain information provided by students on their Free Application for Federal Student Aid (FAFSA) and update any discrepancies in the COD system. Accurate and timely updates to COD are essential to ensure the proper administration of federal student aid programs and to prevent improper payments. According to 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our audit of the District's student financial aid program, we identified that verification information for 1 (3%) of 40 students tested had a discrepancy between the information in their financial aid file and the data reported in the Common Origination and Disbursement (COD) system. Questioned costs: None Context: The District participates in federal student aid programs, which require strict adherence to federal regulations regarding the verification of student information. Verification is a process mandated by the U.S. Department of Education to confirm the accuracy of information provided by students on their FAFSA. Institutions must verify certain data elements and update any discrepancies in the COD system. Accurate and timely updates to COD are essential to ensure the proper administration of federal student aid programs, prevent improper payments, and maintain the integrity of the financial aid process. Cause: The discrepancy was primarily due to a lack of adequate internal controls and oversight in the verification process to consistently and accurately update the COD system. Effect: Failure to update verification information in COD can lead to incorrect disbursement of federal student aid funds, potentially resulting in overpayments or underpayments, and can affect the institution's eligibility to participate in these programs. Repeat finding: No Recommendation: We recommend the District implement stronger internal controls and oversight procedures to ensure that all verification information is accurately and timely updated in the COD system. This may include additional training for financial aid staff, regular reconciliation of financial aid files with COD data, and periodic internal audits to ensure compliance with federal regulations. Views of responsible officials: Students in the Pell Grant Verification Status (PGVS) file will be reviewed by a Financial Assistance Advisor for Pell and another Financial Assistance Advisor for Verification to make sure all appropriate flags are set correctly in the system. Once this review is complete, Pell will be re-originated. If students persist in the PGVS file, a help desk ticket will be filled with our Information Technology department to investigate why the record is still showing as not verified. This new review process will provide additional oversight in the verification process.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 (Federal Pell Grant Program), 84.007 (Supplemental Educational Opportunity Grant), 84.033 (College Work Study), 84.268 (Federal Direct Student Loans Program), Federal Award Identification Number and Year: N/A; 2023-2024 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: According to 34 CFR 668.55, institutions are required to verify certain information provided by students on their Free Application for Federal Student Aid (FAFSA) and update any discrepancies in the COD system. Accurate and timely updates to COD are essential to ensure the proper administration of federal student aid programs and to prevent improper payments. According to 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our audit of the District's student financial aid program, we identified that verification information for 1 (3%) of 40 students tested had a discrepancy between the information in their financial aid file and the data reported in the Common Origination and Disbursement (COD) system. Questioned costs: None Context: The District participates in federal student aid programs, which require strict adherence to federal regulations regarding the verification of student information. Verification is a process mandated by the U.S. Department of Education to confirm the accuracy of information provided by students on their FAFSA. Institutions must verify certain data elements and update any discrepancies in the COD system. Accurate and timely updates to COD are essential to ensure the proper administration of federal student aid programs, prevent improper payments, and maintain the integrity of the financial aid process. Cause: The discrepancy was primarily due to a lack of adequate internal controls and oversight in the verification process to consistently and accurately update the COD system. Effect: Failure to update verification information in COD can lead to incorrect disbursement of federal student aid funds, potentially resulting in overpayments or underpayments, and can affect the institution's eligibility to participate in these programs. Repeat finding: No Recommendation: We recommend the District implement stronger internal controls and oversight procedures to ensure that all verification information is accurately and timely updated in the COD system. This may include additional training for financial aid staff, regular reconciliation of financial aid files with COD data, and periodic internal audits to ensure compliance with federal regulations. Views of responsible officials: Students in the Pell Grant Verification Status (PGVS) file will be reviewed by a Financial Assistance Advisor for Pell and another Financial Assistance Advisor for Verification to make sure all appropriate flags are set correctly in the system. Once this review is complete, Pell will be re-originated. If students persist in the PGVS file, a help desk ticket will be filled with our Information Technology department to investigate why the record is still showing as not verified. This new review process will provide additional oversight in the verification process.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 (Federal Pell Grant Program), 84.007 (Supplemental Educational Opportunity Grant), 84.033 (College Work Study), 84.268 (Federal Direct Student Loans Program), Federal Award Identification Number and Year: N/A; 2023-2024 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: According to 34 CFR 668.55, institutions are required to verify certain information provided by students on their Free Application for Federal Student Aid (FAFSA) and update any discrepancies in the COD system. Accurate and timely updates to COD are essential to ensure the proper administration of federal student aid programs and to prevent improper payments. According to 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our audit of the District's student financial aid program, we identified that verification information for 1 (3%) of 40 students tested had a discrepancy between the information in their financial aid file and the data reported in the Common Origination and Disbursement (COD) system. Questioned costs: None Context: The District participates in federal student aid programs, which require strict adherence to federal regulations regarding the verification of student information. Verification is a process mandated by the U.S. Department of Education to confirm the accuracy of information provided by students on their FAFSA. Institutions must verify certain data elements and update any discrepancies in the COD system. Accurate and timely updates to COD are essential to ensure the proper administration of federal student aid programs, prevent improper payments, and maintain the integrity of the financial aid process. Cause: The discrepancy was primarily due to a lack of adequate internal controls and oversight in the verification process to consistently and accurately update the COD system. Effect: Failure to update verification information in COD can lead to incorrect disbursement of federal student aid funds, potentially resulting in overpayments or underpayments, and can affect the institution's eligibility to participate in these programs. Repeat finding: No Recommendation: We recommend the District implement stronger internal controls and oversight procedures to ensure that all verification information is accurately and timely updated in the COD system. This may include additional training for financial aid staff, regular reconciliation of financial aid files with COD data, and periodic internal audits to ensure compliance with federal regulations. Views of responsible officials: Students in the Pell Grant Verification Status (PGVS) file will be reviewed by a Financial Assistance Advisor for Pell and another Financial Assistance Advisor for Verification to make sure all appropriate flags are set correctly in the system. Once this review is complete, Pell will be re-originated. If students persist in the PGVS file, a help desk ticket will be filled with our Information Technology department to investigate why the record is still showing as not verified. This new review process will provide additional oversight in the verification process.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 (Federal Pell Grant Program), 84.007 (Supplemental Educational Opportunity Grant), 84.033 (College Work Study), 84.268 (Federal Direct Student Loans Program), Federal Award Identification Number and Year: N/A; 2023-2024 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: According to 34 CFR 668.55, institutions are required to verify certain information provided by students on their Free Application for Federal Student Aid (FAFSA) and update any discrepancies in the COD system. Accurate and timely updates to COD are essential to ensure the proper administration of federal student aid programs and to prevent improper payments. According to 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our audit of the District's student financial aid program, we identified that verification information for 1 (3%) of 40 students tested had a discrepancy between the information in their financial aid file and the data reported in the Common Origination and Disbursement (COD) system. Questioned costs: None Context: The District participates in federal student aid programs, which require strict adherence to federal regulations regarding the verification of student information. Verification is a process mandated by the U.S. Department of Education to confirm the accuracy of information provided by students on their FAFSA. Institutions must verify certain data elements and update any discrepancies in the COD system. Accurate and timely updates to COD are essential to ensure the proper administration of federal student aid programs, prevent improper payments, and maintain the integrity of the financial aid process. Cause: The discrepancy was primarily due to a lack of adequate internal controls and oversight in the verification process to consistently and accurately update the COD system. Effect: Failure to update verification information in COD can lead to incorrect disbursement of federal student aid funds, potentially resulting in overpayments or underpayments, and can affect the institution's eligibility to participate in these programs. Repeat finding: No Recommendation: We recommend the District implement stronger internal controls and oversight procedures to ensure that all verification information is accurately and timely updated in the COD system. This may include additional training for financial aid staff, regular reconciliation of financial aid files with COD data, and periodic internal audits to ensure compliance with federal regulations. Views of responsible officials: Students in the Pell Grant Verification Status (PGVS) file will be reviewed by a Financial Assistance Advisor for Pell and another Financial Assistance Advisor for Verification to make sure all appropriate flags are set correctly in the system. Once this review is complete, Pell will be re-originated. If students persist in the PGVS file, a help desk ticket will be filled with our Information Technology department to investigate why the record is still showing as not verified. This new review process will provide additional oversight in the verification process.
Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425U – COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER III) Department of Education, Passed-Through Colorado Department of Education Award Number – 4414/4431/9414; Award Year 2021 Criteria: According to 2 CFR Part 200.403 factors affecting allowability of costs – costs must meet the following general criteria in order to be allowable under Federal awards: (a) be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity, (d) be accorded consistent treatment, (e) be determined in accordance with generally accepted accounting principles, (f) to be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period and (g) be adequately documented. In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing we noted the following: a. 3 out of the 25 payroll selections applied to the grant did not agree back to supporting payroll information. b. The indirect costs applied to the grant were not consistently applied between the quarters of the fiscal year due to variations in the indirect cost base used. Questioned Costs: a. $2,089. Questioned costs were determined by reviewing the payroll registers for the three impacted selections. b. None. The District under applied the amount of indirect costs allowable to the grant. Context: a. We tested 25 payroll, 25 nonpayroll and 25 fringe benefit transactions applied to the grant for the year ended June 30, 2024. The tested population covered expenditures of $7.1 million and the total population of expenditures were approximately $24.4 million. A non-statistical sampling methodology was used to select the sample. b. We tested the four quarters indirect costs calculations which were applied to the above grant award numbers for the year ended June 30, 2024. The tested population covered expenditures of $3.0 million and the total population of expenditures were approximately $3.1 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER grant which resulted in unallowable costs being applied to the grant and inconsistently applying indirect costs to the grant. Cause: The District continued to experience turnover within the positions overseeing grants during fiscal year 2024. There were not detailed reviews over the calculations and supporting documentation used to determine the expenditure amount to be applied to the grant. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the District strengthen the internal controls surrounding review of all expenditures applied against federal grants including the supporting detail or calculations used to determine the expenditure amount to help ensure it recalculates and is consistent with District polices and procedures. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.
Finding: Special Tests – Wage Rate Requirements Federal Assistance Listing Number 84.425U – COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER III) Department of Education, Passed-Through Colorado Department of Education Award Number – 4414/4431/9414; Award Year 2021 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have controls in place to identify that certified payrolls were not obtained for all subcontractors for construction projects which occurred during fiscal year 2024. Questioned Costs: None. Upon additional audit follow up requests, the contractor confirmed no work was performed during these weeks by the subcontractor. Context: We tested two construction projects out of the four construction projects which occurred during the year ended June 30, 2024. The tested population covered expenditures of $3.6 million and the total population of expenditures were approximately $6.5 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over to ensure that all certified payrolls were not obtained or reviewed for both the contractor and subcontractor so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The assigned employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors was out of the office for a portion of the year and the District did not have any employees trained as a backup. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the District implement additional internal controls over wage rate requirements, including cross-training employees to help ensure all certified payrolls or confirmation of no work performed are obtained timely. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
Suspension Debarment Federal Agency: U.S. Federal Government Federal Program Title: Integrative Activities, Research and Development Cluster Assistance Listing Number: 47.083 Federal Award Identification Number and Year: 2320040-2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. In addition, per the Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University was not able to provide a verification check occurring before entering into contract with a vendor/subrecipient. Context: During our testing of 5 contracts, we identified one vendor/subrecipient that the University could not provide a verification check prior to entering the contract. Questioned costs: None. Cause: Verification check did not occur before entering into contract with vendor/subrecipient. Effect: The University entered into contract with a vendor/subrecipient prior to performing a verification check. Repeat finding: Yes, 2023-004 Recommendation: We recommend the University evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor/subrecipient. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Cash Management-Subrecipient Federal Agency: U.S. Federal Government Federal Program Title: Research and Development Cluster Assistance Listing Number: 93.859; 47.074 Federal Award Identification Number and Year: 1R01GM137083 – 2024; 2317969 - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(4)). In addition, per the Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Three subrecipient invoices, totaling $29,306, out of 5 tested, totaling $60,038, were not paid within the required 30 days. Questioned costs: None. Cause: Procedures were not in place to ensure subrecipients were paid within 30 days of receipt of the invoices. Effect: Subrecipients did not receive their reimbursement timely. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Procurement Federal Agency: U.S. Federal Government Federal Program Title: Integrative Activities, Research and Development Cluster Assistance Listing Number: 47.083 Federal Award Identification Number and Year: CE2559-SB-873905 A2, A3 - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not complete documentation for reasonings of why they did not obtain price quotes or competitive bids prior to entering the transaction. Context: During our testing we identified 1 of the 5 contracts tested did not include adequate documentation to award the contracts without price quotations or a competitive bid process. Questioned costs: $39,160 Cause: Lack of training for procurement personnel regarding federal funds passed through State agencies to the University. Effect: Documentation for why the University did not obtain price quotes or competitive bids was not documented in a timely manner. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures and implement an additional control to document reasons for not obtaining price quotes or competitive bids prior to entering the transaction. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Eligibility - Pell Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The University under-awarded funds for the Pell Grant. Context: During our testing we noted one of forty students, from a statistically valid sample, were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None Cause: The report generated to capture Summer term students who did not self-identify for Summer Aid consideration but qualified for Pell funds did not capture this student due to system changes that were not accounted for in the SQL. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat finding: No Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Eligibility - Pell Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The University under-awarded funds for the Pell Grant. Context: During our testing we noted one of forty students, from a statistically valid sample, were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None Cause: The report generated to capture Summer term students who did not self-identify for Summer Aid consideration but qualified for Pell funds did not capture this student due to system changes that were not accounted for in the SQL. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat finding: No Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Special Tests & Provisions Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Cash Management-Subrecipient Federal Agency: U.S. Federal Government Federal Program Title: Research and Development Cluster Assistance Listing Number: 93.859; 47.074 Federal Award Identification Number and Year: 1R01GM137083 – 2024; 2317969 - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(4)). In addition, per the Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Three subrecipient invoices, totaling $29,306, out of 5 tested, totaling $60,038, were not paid within the required 30 days. Questioned costs: None. Cause: Procedures were not in place to ensure subrecipients were paid within 30 days of receipt of the invoices. Effect: Subrecipients did not receive their reimbursement timely. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.038 – Federal Perkins Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: 2 CFR 200.303 Code of Federal Regulations Title 34, Subtitle B, Chapter VI, Part 674.19 requires that in administering its Federal Perkins Loan program, an institution shall establish and maintain an internal control system of checks and balances that ensures that no office can both authorize payments and disburse funds to students. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicer’s most recent Title IV compliance audit. Condition: The University utilizes a third party service provider for its Perkins Loan servicing. Federal regulations require the institution to perform due diligence on the third party servicer to ensure they are following federal regulations. The institution was not able to perform their due diligence for fiscal year 2024 since the third party service provider’s 2024 Title IV compliance audit was not completed as of issuance of audit. Questioned Costs: None Context: The due diligence typically performed by the institution is the review of the third party servicer's compliance report. However, the third party servicer was delayed in having this report issued. The institution did not have an alternate plan for performing due diligence over the third party servicer. Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2024 so that the University could perform their required due diligence on the third party servicer and the institution did not have an alternate plan established. Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to perform. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Internal controls over cash management compliance requirements to be reviewed Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 84.425, Department of Education, Education Stabilization Fund and 84.367, Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) Federal Award Identification Number and Year: 213713 & 240520 Pass-through Entity: Michigan Department of Education Finding Type: Material weakness in internal control over compliance Criteria: Per 2 CFR § 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing for cash management, it was noted that 2 out of 2 drawdown requests selected for testing did not have evidence of review and approval. Cause: Management did not fully implement their internal control policies and procedures as there was no evidence of review and approvals, nor was documentation retained. Effect: Drawdown requests did not have evidence of review and approval. Recommendation: We recommend that management review its procedures and controls in place to ensure that reports and supporting documentation are retained and have proper evidence of review and approval. View of responsible officials and planned corrective action plan: Management agrees with the finding. See corrective action plan.
Internal controls over reporting compliance requirements to be reviewed Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 84.425, Department of Education, Education Stabilization Fund and 84.367, Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) Federal Award Identification Number and Year: 213713 & 240520 Pass-through Entity: Michigan Department of Education Finding Type: Material weakness in internal control over compliance Criteria: Per 2 CFR § 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing for reporting, it was noted that 1 out of 1 report selected for testing did not have evidence of review and approval. Cause: Management did not fully implement their internal control policies and procedures as there was no evidence of review and approvals, nor was documentation retained. Effect: Reports did not have evidence of review and approval. Recommendation: We recommend that management review its procedures and controls in place to ensure that reports and supporting documentation are retained and have proper evidence of review and approval. View of responsible officials and planned corrective action plan: Management agrees with the finding. See corrective action plan.
Internal controls over activities allowed or unallowed and allowable cost and cost principles compliance requirements to be reviewed Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 84.425, Department of Education, Education Stabilization Fund and 84.367, Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) Federal Award Identification Number and Year: 213713 & 240520 Pass-through Entity: Michigan Department of Education Finding Type: Material weakness in internal control over compliance Repeat Finding: No Criteria: Per 2 CFR § 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing for activities allowed or unallowed, allowable costs/cost principles, it was noted that 6 out of 6 payroll related disbursements selected for testing did not have evidence of review and approval. Cause: Management did not fully implement their internal control policies and procedures as there was no evidence of review and approvals, nor was documentation retained. Effect: Payroll related reports did not have evidence of review and approval. Recommendation: We recommend that management review its procedures and controls in place to ensure that reports and supporting documentation are retained and have proper evidence of review and approval. View of responsible officials and planned corrective action plan: Management agrees with the finding. See corrective action plan.
Internal controls over cash management compliance requirements to be reviewed Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 84.425, Department of Education, Education Stabilization Fund and 84.367, Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) Federal Award Identification Number and Year: 213713 & 240520 Pass-through Entity: Michigan Department of Education Finding Type: Material weakness in internal control over compliance Criteria: Per 2 CFR § 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing for cash management, it was noted that 2 out of 2 drawdown requests selected for testing did not have evidence of review and approval. Cause: Management did not fully implement their internal control policies and procedures as there was no evidence of review and approvals, nor was documentation retained. Effect: Drawdown requests did not have evidence of review and approval. Recommendation: We recommend that management review its procedures and controls in place to ensure that reports and supporting documentation are retained and have proper evidence of review and approval. View of responsible officials and planned corrective action plan: Management agrees with the finding. See corrective action plan.
Internal controls over reporting compliance requirements to be reviewed Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 84.425, Department of Education, Education Stabilization Fund and 84.367, Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) Federal Award Identification Number and Year: 213713 & 240520 Pass-through Entity: Michigan Department of Education Finding Type: Material weakness in internal control over compliance Criteria: Per 2 CFR § 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing for reporting, it was noted that 1 out of 1 report selected for testing did not have evidence of review and approval. Cause: Management did not fully implement their internal control policies and procedures as there was no evidence of review and approvals, nor was documentation retained. Effect: Reports did not have evidence of review and approval. Recommendation: We recommend that management review its procedures and controls in place to ensure that reports and supporting documentation are retained and have proper evidence of review and approval. View of responsible officials and planned corrective action plan: Management agrees with the finding. See corrective action plan.
Internal controls over activities allowed or unallowed and allowable cost and cost principles compliance requirements to be reviewed Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 84.425, Department of Education, Education Stabilization Fund and 84.367, Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) Federal Award Identification Number and Year: 213713 & 240520 Pass-through Entity: Michigan Department of Education Finding Type: Material weakness in internal control over compliance Repeat Finding: No Criteria: Per 2 CFR § 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing for activities allowed or unallowed, allowable costs/cost principles, it was noted that 6 out of 6 payroll related disbursements selected for testing did not have evidence of review and approval. Cause: Management did not fully implement their internal control policies and procedures as there was no evidence of review and approvals, nor was documentation retained. Effect: Payroll related reports did not have evidence of review and approval. Recommendation: We recommend that management review its procedures and controls in place to ensure that reports and supporting documentation are retained and have proper evidence of review and approval. View of responsible officials and planned corrective action plan: Management agrees with the finding. See corrective action plan.
Internal controls over cash management compliance requirements to be reviewed Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 84.425, Department of Education, Education Stabilization Fund and 84.367, Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) Federal Award Identification Number and Year: 213713 & 240520 Pass-through Entity: Michigan Department of Education Finding Type: Material weakness in internal control over compliance Criteria: Per 2 CFR § 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing for cash management, it was noted that 2 out of 2 drawdown requests selected for testing did not have evidence of review and approval. Cause: Management did not fully implement their internal control policies and procedures as there was no evidence of review and approvals, nor was documentation retained. Effect: Drawdown requests did not have evidence of review and approval. Recommendation: We recommend that management review its procedures and controls in place to ensure that reports and supporting documentation are retained and have proper evidence of review and approval. View of responsible officials and planned corrective action plan: Management agrees with the finding. See corrective action plan.