Finding Text
Summary Statement of Condition:
The University failed to timely submit the 2022 reporting package [2 CFR §200.512(c)] required by Government Auditing Standards and Uniform Guidance per 2 CFR §200.512(a)(1).
Criteria:
The audit must be completed and the data collection form described in paragraph (b) of section §200.512 and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal Holiday, the reporting package is due the next business day.
In this case, the reporting package was due on October 2, 2023. This reporting package was completed on February 16, 2024 and available to be submitted on February 27, 2024.
Effect:
The University’s failure to timely submit the reporting package when due may adversely affect the Department of Education’s ability to timely take action that could prevent loss of SFA funds.
Cause:
The University has never been late in submission of its audit report. The University has not ever had findings of material or significant control or compliance failures. The failure to timely submit its 2022 reporting package is unprecedented.
As explained below, due to an unusual series of events, the University lost the ability to promptly provide the auditor with the historic records needed by the auditor to complete the SFA part of the audit. It took until January 24, 2024 for the University to access and forward some basic SFA record to the auditor.
In 2023, there were multiple changes in the University’s Financial Aid Director and persons responsible for maintaining historic SFA records.
Edgar Trovada was the Financial Aid Director for several years. Mr. Trovada retired from the University in March 2022. He maintained records in ED Express. Unfortunately, the University discovered later that the 2022 ED Express files were lost sometime after his departure.
On April 15, 2022, The University’s new CFO Bruce Kariya engaged Third Coast Education (3rd Coast) as the financial aid third-party servicer while seeking resident Financial Aid Director.
Long time University employee Tora Flint was appointed the campus based Interim Financial Aid Director. The arrangement with 3rd Coast as SFA servicer continued while Ms. Flint provided student facing SFA services to ensure proper award and delivery of 2023 SFA.
Mr. Kariya left the University at the end of April 2023.
In August 2023, Michael Mathis was appointed as the Financial Aid Director. Mr. Mathis acquired rights to access ED Connect. The rights held by 3rd Coast were inadvertently terminated.
Mr. Mathis suddenly resigned after 3 weeks on the job.
The University failed to update the Department of Education on the departure of Mr. Mathis, and thus access to the historic records through ED Connect was lost. The University’s efforts to re-establish access faced difficulties and delays. The University and 3rd Coast sought to re-establish its rights with the Department of Education.
3rd Coast is a company consisting of two individuals, the principal Mr. Eric Weems and Ms. Hayden Wager. Mr. Weems was ill and died on January 16, 2024, disrupting the attempts to obtain records needed for the 2022 SFA audit.
It was not until February 16, 2024, that the historic 2022 SFA records were provided to the auditor.
Recommendation for Corrective Action:
The University must have two persons with access to ED Express and officially authorized to access ED records at all times.
Procedures must be established to promptly and accurately notify the Department of Education of changes in personnel with rights to access of ED records.
The University should maintain current and historic SFA relevant records under its control preferably in digital format. There should be proven backup and restore capabilities. The University should adopt appropriate checklist to ensure retention and ability to promptly restore complete SFA records for all SFA students and the University.