Husson University

Finding 2025-001 Program Affected AL 21.027 Coronavirus State and Local Fiscal Recovery Funds – Agreement period September 15, 2022 through June 30, 2026 Criteria 2 CFR 180.300 details the requirement when, “entering a covered transaction with another person at the next lower tier, they must verify that the person with whom they intend to do business is not excluded or disqualified. This is done by (a) checking SAM exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person.” Condition and Context In consideration of procurement, and suspension and debarment under this program, the University did not have auditable evidence of testing vendors with the requirements of 2 CFR 180.300 for verifying a vendor is not excluded or disqualified from doing business with an entity that receives federal funds. We selected three vendors and five employees to compare to the exclusion system and did not identify any excluded parties in our testing. Questioned Costs None noted. Cause and Effect The University currently lacks a formal process to review vendors against the System for Award Management (SAM) exclusion list, collecting a formal certification from the vendor or adding a clause to the covered transaction with the vendor. Without a formal policy addressing the process of suspension and debarment check, there is risk of working with a suspended or debarred entity resulting in noncompliant use of federal funds. Recommendation We recommend implementing a formal process when entering arrangements with external parties to check they are not suspended or debarred on the SAM Exclusions list. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.

Programs Affected U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2023 – June 30, 2024: 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.” Condition While testing return of Title IV funds (R2T4), a nonstatistical sample of 25 students was tested for proper return calculations. The University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. Cause The University process was to perform a documented review of R2T4 calculations only when a student was determined not to have earned 100% of their aid, and thus the documented review was not completed for the 2 of 25 calculations sampled. Questioned Costs None. Effect Without proper review, an error in the R2T4 calculation could be missed, causing incorrect refunds and non-compliance with regulations. Identification as a Repeat Finding, if Applicable Not applicable. Recommendation BD recommends the process be revised to require review of the R2T4 calculations regardless of determined aid earned percentage. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.

Finding 2023-001 Programs Affected Under the Student Financial Assistance Cluster – Award Year July 1, 2022 – June 30, 2023: AL 84.268 – U.S. Department of Education – Federal Direct Student Loans Criteria Per 34 Code of Federal Regulations (CFR) 668.165, the institution must notify the student in writing of the student’s right to cancel all or a portion of a loan and to have the loan proceeds returned to the holder, no later than 30 days after crediting the student’s account with the Federal Direct Student Loan. Condition Based on a nonstatistical sample of 25 selections from the Federal Direct Student Loan population, four of the selections did not receive a written notification of the right to cancel within the required timeframe. Cause The notification process is automated and there was a system error during a mass electronic email distribution notification. Questioned Costs None. Effect A population of students did not get notified of their right to cancel direct loans within 30 days. Identification as a Repeat Finding, if Applicable Not applicable. Recommendation BerryDunn recommends the reviewer manually check the student account correspondence log within the system following the email notifications to determine accuracy and completeness. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.

Finding 2023-002 Programs Affected U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2022 – June 30, 2023. Criteria According to 34 CFR section 668.22, a school is required to determine the earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student is in attendance or, in the case of a clock-hour program, was scheduled to be in attendance. 34 CFR Section 668.2 (f)(2)(i) further states that the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition While testing return of Title IV funds, a nonstatistical sample of 6 students was tested for proper return calculations. During the testing, we noted the calculation for the 2022 fall semester return of funds was based on an incorrect number of days due to the inclusion of the academic break surrounding the Thanksgiving holiday. From the total population of students that had a return of Title IV funds, 25 students who withdrew were impacted, resulting in additional funds needing to be returned to the Department of Education. This prompted the University to review the 2023 spring semester return of funds as well, which caused seven more students who withdrew to be impacted, resulting in additional funds needing to be returned to the Department of Education. Cause The calculation of total days was miscalculated causing the percentage earned and unearned by Title IV students that withdrew. Questioned Costs $5,875; $5,743 for the fall semester and $132 for the spring semester. Effect Students withdrawing had improper calculations of aid earned and unearned due to the miscalculated total number of days. Fall semester had 25 students and spring semester had 7 students that needed to have the return of Title IV funds calculation re-performed. All 32 students required more funds to be returned to the Department of Education. The University returned the funds using institutional funds. Recommendation BerryDunn recommends the return of Title IV funds worksheet include a documented review process around parameters for academic breaks included in a semester. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.

Programs Affected Under the Student Financial Assistance Cluster - Award Year July 1, 2020 ? June 30, 2021: CFDA 84.268 ? U.S. Department of Education ? Federal Direct Student Loans Criteria According to 34 CFR 6.309(b)(2) ? Direct Loans, Enrollment Reporting: unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and (ii) the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a halftime basis for the period for which the loan was intended. Condition Noted 1 of 25 selections, from a nonstatistical sample, tested of the reporting to the NSLDS for loan recipients? change in enrollment status, had a change in status was not reported within the required timeframe. Context The notification process is automated and it was discovered a field in CAMS (The University?s student database) was not populated, resulting in the omission of 30 graduate students. Of the 30 graduate students only 15 received aid. Questioned Costs: None Cause and Effect A population of students did not get reported to the clearinghouse timely, which would result in delay of repayment period. Identification as a Repeat Finding, if Applicable Yes, 2020-002. Recommendation BerryDunn recommends the University regularly monitor the submissions to clearinghouse to verify the accuracy on a timely basis. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.

Finding 2021-002 Programs Affected Under the Student Financial Assistance Cluster - Award Year July 1, 2020 ? June 30, 2021: CFDA 84.268 ? U.S. Department of Education ? Federal Direct Student Loans Criteria According to 34 CFR 685.309(b)(2) ? Direct Loans, Enrollment Reporting: unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and (ii) the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a halftime basis for the period for which the loan was intended. Condition Noted 1 of 25 students selected for testing, from a nonstatistical sample, of the reporting to the National Students Loan Data System (NSLDS) for change in the loan recipients? enrollment status, had a change in status which was not reported correctly. This student was reported as half-time and should have been reported as withdrawn. Context: This appears to have been an isolated incident as the student was attending a 7 week term in the Spring of 2021 semester and then withdrew. If a traditional semester, this would have appeared as a half time status rather than mid-semester withdrawal. Therefore the system reflected as half-time in error. Questioned Costs None Cause and Effect Status was not reported correctly which would have an effect on when the student?s repayment period starts. Recommendation We recommend reviews are manually performed in order to capture Student Status Changes accurately. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.

Programs Affected Under the Student Financial Assistance Cluster - Award Year July 1, 2019 ? June 30, 2020: CFDA 84.268 ? U.S. Department of Education ? Federal Direct Student Loans Criteria 34 CFR section 668.165 ? The institution must notify the student or parent Direct Loan borrower in writing of the student?s right, or parent?s right, to cancel all or a portion of a Direct Loan and to have the loan proceeds returned to the holder, no later than 30 days after crediting the student?s account with the Direct Loan. Condition The University found the notifications that were scheduled to be made on December 10, 2019, using their automated process, failed to transmit and therefore students did not receive the required notifications for Direct Loan funds. The University subsequently notified these students or parents following the identification of the error in June 2020. As a result of the error in the automated process, an estimated 2,583 students or parents did not receive timely written notice of their right to cancel their Direct Loans. Context The notification process is automated and there appears to have been a system error during an electronic email mass distribution notification, which resulted in a delay in subsequent notifications until the error was identified. Questioned Costs None Cause and Effect A population of students or parents were not notified of their right to cancel their Direct Loans timely, which could result in inadvertent Direct Loan borrowings. Recommendation BerryDunn recommends the University regularly monitor the student account correspondence log following automated notifications, to verify the required notifications occur on a timely basis. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.

Programs Affected Under the Student Financial Assistance Cluster - Award Year July 1, 2019 ? June 30, 2020: CFDA 84.268 ? U.S. Department of Education ? Federal Direct Student Loans Criteria According to 34 CFR 685.309(b)(2) ? Direct Loans, Enrollment Reporting: unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and (ii) the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition Noted 1 of 25 students selected for testing of the reporting to the National Students Loan Data System (NSLDS) for change in the loan recipients? enrollment status, had a change in status which was not reported correctly or within the required timeframe. Context In the Fall 2019, the University?s automated process for updating the data reported to NSLDS inadvertently excluded changes that occurred after the start of the term for students enrolled in the 7-week terms. The failure to update the data properly was a result of an error in the implementation of custom code meant to allow the University to report to NSLDS data for these 7-week terms. The code was implemented partway through the Fall term and the Registrar discovered the problem on January 8th, 2020 and promptly resolved the error. Questioned Costs None Cause and Effect Withdrawal dates were not reported within the required timeframe, which may result in the students entering repayment status later than the required timeframe. Recommendation We recommend a manual check be completed upon implementation of automated processes and periodic checks be performed thereafter to allow for timely reporting of student status changes to NSLDS. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.

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