EIN: 030482006
UEI: J8LJEM6B33Q3
Audited by: HILL, BARTH & KING LLC
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 3, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 3, 2026 (3 days from today).
What is a management decision? →FAC accepted this audit on November 7, 2024 — management decision was due May 7, 2025.
FAC accepted this audit on December 19, 2023 — management decision was due June 19, 2024.
Per review of the University’s annual report, we noted three instances where the amounts and information reported did not agree to the internal records. Issues noted included incorrect amounts and information posted for the Emergency Financial Aid grants, monitoring and suppressing coronavirus, and total of institutional annual expenditures. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the Department of Education to ensure the annual report was posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the program does not have accurate information regarding how HEERF program funds were expended by the University. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the Department of Education and other regulators. Auditee's Response: The reports will be monitored more closely going forward. See attached corrective action plan.
Show full finding ▾Hide full finding ▴Finding: 2023-002 Program Affected: COVID-19 Higher Education Emergency Relief Fund (HEERF) (AL Number 84.425E) Finding Type: Significant deficiency on internal control Criteria: The HEERF I, II, and III funding came with various requirements instituted by the CARES Act, CRRSAA, and ARP and then further defined by the US Department of Education (ED). The ED exercised its reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329 to define three reporting requirements for the HEERF program funds, which include 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. These reporting requirements stipulate specific guidelines regarding when, how, and what information is to be reported on quarterly and the annual reports. Condition: Per review of the University’s annual report, we noted three instances where the amounts and information reported did not agree to the internal records. Issues noted included incorrect amounts and information posted for the Emergency Financial Aid grants, monitoring and suppressing coronavirus, and total of institutional annual expenditures. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the Department of Education to ensure the annual report was posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the program does not have accurate information regarding how HEERF program funds were expended by the University. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the Department of Education and other regulators. Auditee's Response: The reports will be monitored more closely going forward. See attached corrective action plan.
The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of each of the 48 pages) makes review before submission extremely difficult. There were literally hundreds of entries in this report, and there were three errors, each of which reflected information that was reported accurately in the quarterly reports posted on the University’s website. Despite the unfortunate design constraints, the University will endeavor to identify a practical way to conduct a review of the annual report before submission next spring. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin
Per review of the University’s annual report, we noted three instances where the amounts and information reported did not agree to the internal records. Issues noted included incorrect amounts and information posted for the Emergency Financial Aid grants, monitoring and suppressing coronavirus, and total of institutional annual expenditures. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the Department of Education to ensure the annual report was posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the program does not have accurate information regarding how HEERF program funds were expended by the University. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the Department of Education and other regulators. Auditee's Response: The reports will be monitored more closely going forward. See attached corrective action plan.
Show full finding ▾Hide full finding ▴Finding: 2023-002 Program Affected: COVID-19 Higher Education Emergency Relief Fund (HEERF) (AL Number 84.425E) Finding Type: Significant deficiency on internal control Criteria: The HEERF I, II, and III funding came with various requirements instituted by the CARES Act, CRRSAA, and ARP and then further defined by the US Department of Education (ED). The ED exercised its reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329 to define three reporting requirements for the HEERF program funds, which include 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. These reporting requirements stipulate specific guidelines regarding when, how, and what information is to be reported on quarterly and the annual reports. Condition: Per review of the University’s annual report, we noted three instances where the amounts and information reported did not agree to the internal records. Issues noted included incorrect amounts and information posted for the Emergency Financial Aid grants, monitoring and suppressing coronavirus, and total of institutional annual expenditures. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the Department of Education to ensure the annual report was posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the program does not have accurate information regarding how HEERF program funds were expended by the University. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the Department of Education and other regulators. Auditee's Response: The reports will be monitored more closely going forward. See attached corrective action plan.
The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of each of the 48 pages) makes review before submission extremely difficult. There were literally hundreds of entries in this report, and there were three errors, each of which reflected information that was reported accurately in the quarterly reports posted on the University’s website. Despite the unfortunate design constraints, the University will endeavor to identify a practical way to conduct a review of the annual report before submission next spring. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin
FAC accepted this audit on February 23, 2024 — management decision was due August 23, 2024.
Per review of the University’s annual report, we noted three instances where the amounts and information reported did not agree to the internal records. Issues noted included incorrect amounts and information posted for the Emergency Financial Aid grants, monitoring and suppressing coronavirus, and total of institutional annual expenditures. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the Department of Education to ensure the annual report was posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the program does not have accurate information regarding how HEERF program funds were expended by the University. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the Department of Education and other regulators. Auditee's Response: The reports will be monitored more closely going forward. See attached corrective action plan.
Show full finding ▾Hide full finding ▴Finding: 2023-002 Program Affected: COVID-19 Higher Education Emergency Relief Fund (HEERF) (AL Number 84.425E) Finding Type: Significant deficiency on internal control Criteria: The HEERF I, II, and III funding came with various requirements instituted by the CARES Act, CRRSAA, and ARP and then further defined by the US Department of Education (ED). The ED exercised its reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329 to define three reporting requirements for the HEERF program funds, which include 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. These reporting requirements stipulate specific guidelines regarding when, how, and what information is to be reported on quarterly and the annual reports. Condition: Per review of the University’s annual report, we noted three instances where the amounts and information reported did not agree to the internal records. Issues noted included incorrect amounts and information posted for the Emergency Financial Aid grants, monitoring and suppressing coronavirus, and total of institutional annual expenditures. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the Department of Education to ensure the annual report was posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the program does not have accurate information regarding how HEERF program funds were expended by the University. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the Department of Education and other regulators. Auditee's Response: The reports will be monitored more closely going forward. See attached corrective action plan.
The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of each of the 48 pages) makes review before submission extremely difficult. There were literally hundreds of entries in this report, and there were three errors, each of which reflected information that was reported accurately in the quarterly reports posted on the University’s website. Despite the unfortunate design constraints, the University will endeavor to identify a practical way to conduct a review of the annual report before submission next spring. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin
Per review of the University’s annual report, we noted three instances where the amounts and information reported did not agree to the internal records. Issues noted included incorrect amounts and information posted for the Emergency Financial Aid grants, monitoring and suppressing coronavirus, and total of institutional annual expenditures. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the Department of Education to ensure the annual report was posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the program does not have accurate information regarding how HEERF program funds were expended by the University. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the Department of Education and other regulators. Auditee's Response: The reports will be monitored more closely going forward. See attached corrective action plan.
Show full finding ▾Hide full finding ▴Finding: 2023-002 Program Affected: COVID-19 Higher Education Emergency Relief Fund (HEERF) (AL Number 84.425E) Finding Type: Significant deficiency on internal control Criteria: The HEERF I, II, and III funding came with various requirements instituted by the CARES Act, CRRSAA, and ARP and then further defined by the US Department of Education (ED). The ED exercised its reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329 to define three reporting requirements for the HEERF program funds, which include 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. These reporting requirements stipulate specific guidelines regarding when, how, and what information is to be reported on quarterly and the annual reports. Condition: Per review of the University’s annual report, we noted three instances where the amounts and information reported did not agree to the internal records. Issues noted included incorrect amounts and information posted for the Emergency Financial Aid grants, monitoring and suppressing coronavirus, and total of institutional annual expenditures. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the Department of Education to ensure the annual report was posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the program does not have accurate information regarding how HEERF program funds were expended by the University. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the Department of Education and other regulators. Auditee's Response: The reports will be monitored more closely going forward. See attached corrective action plan.
The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of each of the 48 pages) makes review before submission extremely difficult. There were literally hundreds of entries in this report, and there were three errors, each of which reflected information that was reported accurately in the quarterly reports posted on the University’s website. Despite the unfortunate design constraints, the University will endeavor to identify a practical way to conduct a review of the annual report before submission next spring. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin
FAC accepted this audit on January 19, 2023 — management decision was due July 19, 2023.
Per review of the University's quarterly public reporting for the Student Aid Portion, we noted one instance where the amounts and information reported did not adhere to the program requirements. Issues noted included amounts not properly separated between student and institutional fund portions and incorrect amounts and information posted for one period. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the DoE to ensure quarterly reports for the Student Aid Portion were posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the public does not have accurate information regarding how HEERF program funds were expended by the University from the student aid portion. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the DoE and other regulators. Auditee?s Response: The reports will be monitored more closely going forward. See attached corrective action plan. Repeat Finding: Yes, 2021-002
Show full finding ▾Hide full finding ▴Finding: 2022-002 Program Affected: 84.425E, 84.425F Finding Type: Significant deficiency on compliance and control Criteria: The HEERF I, II, and III funding came with various requirements instituted by the CARES Act, CRRSAA, and ARP and then further defined by the US Department of Education (ED). The ED exercised its reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329 to define three reporting requirements for the HEERF program funds, which include 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. These reporting requirements stipulate specific guidelines regarding when, how, and what information is to be publicly posted on the University?s website. Condition: Per review of the University's quarterly public reporting for the Student Aid Portion, we noted one instance where the amounts and information reported did not adhere to the program requirements. Issues noted included amounts not properly separated between student and institutional fund portions and incorrect amounts and information posted for one period. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the DoE to ensure quarterly reports for the Student Aid Portion were posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the public does not have accurate information regarding how HEERF program funds were expended by the University from the student aid portion. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the DoE and other regulators. Auditee?s Response: The reports will be monitored more closely going forward. See attached corrective action plan. Repeat Finding: Yes, 2021-002
Finding Number: 2022-002 Planned Corrective Action: The Business office has endeavored to keep pace with the shifting and changing guidance that is promulgated by the Department of Education. This has been a challenge. The Chief Financial Officer continues to monitor any guidance updates and make the appropriate changes to the reports to ensure their accuracy. There was only one report posted that contained one typographical error, but it is the University?s responsibility to ensure the accuracy of the reports and these reports will be monitored more closely going forward. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin
2021-002
FAC accepted this audit on December 9, 2021 — management decision was due June 9, 2022.
Per review of the University?s quarterly public reporting for HEERF I, II, and III funds, we noted several instances where the amounts and information reported did not adhere to the program requirements. Issues noted included amounts not properly separated between student and institutional fund portions, untimely posted reports for HEERF II and III funds, and amounts posted on incorrect lines and at incorrect amounts for the institutional funds expended. Questioned Costs: None Context: Reporting requirements posted by the ED for HEERF program funds were originally posted on May 6, 2020, revised on August 31, 2020, amended on September 23, 2021, and revised again on May 13, 2021. The guidelines have continuously changed and have been intended to be made clearer with each subsequent revision. The University acknowledged it was late in posting quarterly reports after the May 13, 2021 ruling. In addition, it is difficult to draw conclusions on some of the reporting guidance. Cause: There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the ED to ensure quarterly reports were posted accurately. The ED posted a public notice on May 13, 2021 regarding the public reporting requirements for higher education emergency relief grants to students under the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) and American Rescue Plan Act, 2021 (ARP) section (a)(1) and (a)(4) programs. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the public does not have accurate information regarding how HEERF program funds were expended by university from student portion and institutional portion funds. Recommendation: The University should monitor requirements frequently for COVID-19 related HEERF programs. In addition, controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the requirements published by the ED and other regulators. Auditee?s Response: See attached corrective action plan. Repeat Finding: No
Show full finding ▾Hide full finding ▴Finding: 2021-002 Year Affected: June 30, 2021 Finding Type: Significant deficiency on compliance and control Criteria: The HEERF I, II, and III funding came with various requirements instituted by the CARES Act, CRRSAA, and ARP and then further defined by the US Department of Education (ED). The ED exercised its reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329 to define three reporting requirements for the HEERF program funds, which include 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. These reporting requirements stipulate specific guidelines regarding when, how, and what information is to be publicly posted on the University?s website. Condition: Per review of the University?s quarterly public reporting for HEERF I, II, and III funds, we noted several instances where the amounts and information reported did not adhere to the program requirements. Issues noted included amounts not properly separated between student and institutional fund portions, untimely posted reports for HEERF II and III funds, and amounts posted on incorrect lines and at incorrect amounts for the institutional funds expended. Questioned Costs: None Context: Reporting requirements posted by the ED for HEERF program funds were originally posted on May 6, 2020, revised on August 31, 2020, amended on September 23, 2021, and revised again on May 13, 2021. The guidelines have continuously changed and have been intended to be made clearer with each subsequent revision. The University acknowledged it was late in posting quarterly reports after the May 13, 2021 ruling. In addition, it is difficult to draw conclusions on some of the reporting guidance. Cause: There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the ED to ensure quarterly reports were posted accurately. The ED posted a public notice on May 13, 2021 regarding the public reporting requirements for higher education emergency relief grants to students under the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) and American Rescue Plan Act, 2021 (ARP) section (a)(1) and (a)(4) programs. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the public does not have accurate information regarding how HEERF program funds were expended by university from student portion and institutional portion funds. Recommendation: The University should monitor requirements frequently for COVID-19 related HEERF programs. In addition, controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the requirements published by the ED and other regulators. Auditee?s Response: See attached corrective action plan. Repeat Finding: No
Finding Number: 2021-002 Planned Corrective Action: The Business Office has endeavored to keep pace with the shifting and changing guidance that is promulgated by the Department of Education. This has been a challenge. While the HEERF reporting responsibilities had been delegated to a staff member, it has become clear that we need to have multiple individuals following the Department?s regulations in order to ensure that we remain compliant. As such, the Chief Financial Officer will also be monitoring any guidance updates. In addition, we will update and modify, as necessary, any existing reports to ensure their accuracy. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin
FAC accepted this audit on June 28, 2021 — management decision was due December 28, 2021.
Finding 2020-002 Year Affected June 30, 2020 Program Federal Direct Loan Programs (CFDA 84.268) Finding Type Compliance Criteria Under loan programs, institutions must promptly notify the Department of Education (DOE), guaranty agencies or lenders and NSLDS of changes in student status in a timely and accurate manner. Condition One student was awarded an unsubsidized loan and her graduated status was not updated timely in NSLDS. The student?s status change was reported as withdrawn because her courses were not yet complete at the time of the submission to NSLDS, which properly triggered repayment of loans. However, when her status was later determined to be graduated, the University needed to notify NSLDS of the change and this was not completed until discovery during the audit. Questioned Costs None Context Testing resulted in one instance out of eighteen. The financial aid office was able to correct the issue when identified by the audit procedures. Cause When an irregularly timed graduated status is determined for a student, the process was to manually submit the status change to NSLDS. This process relied on one person to complete the change and this was not done. Effect Late and irregular status changes may go undetected and uncorrected. If the University does not notify agencies of status changes through NSLDS in a timely and accurate manner, loan repayment may not be triggered for the student. Recommendation It is recommended additional checks are put into the system to review requirements are met for late graduates. Using a checklist for late graduates will also help insure all items are done timely and accurately with a review process in place. Auditee?s Response See attached corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2020-002 Year Affected June 30, 2020 Program Federal Direct Loan Programs (CFDA 84.268) Finding Type Compliance Criteria Under loan programs, institutions must promptly notify the Department of Education (DOE), guaranty agencies or lenders and NSLDS of changes in student status in a timely and accurate manner. Condition One student was awarded an unsubsidized loan and her graduated status was not updated timely in NSLDS. The student?s status change was reported as withdrawn because her courses were not yet complete at the time of the submission to NSLDS, which properly triggered repayment of loans. However, when her status was later determined to be graduated, the University needed to notify NSLDS of the change and this was not completed until discovery during the audit. Questioned Costs None Context Testing resulted in one instance out of eighteen. The financial aid office was able to correct the issue when identified by the audit procedures. Cause When an irregularly timed graduated status is determined for a student, the process was to manually submit the status change to NSLDS. This process relied on one person to complete the change and this was not done. Effect Late and irregular status changes may go undetected and uncorrected. If the University does not notify agencies of status changes through NSLDS in a timely and accurate manner, loan repayment may not be triggered for the student. Recommendation It is recommended additional checks are put into the system to review requirements are met for late graduates. Using a checklist for late graduates will also help insure all items are done timely and accurately with a review process in place. Auditee?s Response See attached corrective action plan.
Finding Number: 2020-002. Planned Corrective Action: The financial aid department put additional Degree Verify Transmissions in the system at later dates throughout the semester to detect the need to submit graduated status changes in a more timely and accurate manner. This will guarantee late graduates are checked at a later date and prevent similar issues from happening in the future. Anticipated Completion Date: September 2020 Responsible Contact Person: Sandy Shimp, Director of Financial Aid
Finding 2020-003 Year Affected June 30, 2020 Program COVID-19 CARES Act Higher Education Emergency Relief Funding (CFDA 84.425) Finding Type Compliance and Control Criteria Under the CARES Act passed on March 27, 2020, aid was granted to the University under the program Higher Education Emergency Relief Funding (HEERF). This aid was to be used at least 50% towards direct student emergency relief grants (student portion under 84.425E) and the remainder could be used towards institutional needs (84.425F). Both portions of the funds stipulated restrictive use for specific approved purposes. Emergency grants to students under 84.425E could only be provided to students that qualify under Title IV eligibility criteria. Condition The financial aid office was unable to provide documentation of Title IV eligibility for 8 students from the sample of 45 students. Questioned Costs Total questioned costs are estimated to be $37,719: $ 9,825 - 7 student findings $ 27,894 - 1 student finding extrapolated over a sub-population Context An Interim Final Rule was released on June 17, 2020 that required emergency grants to students be only to students eligible under Title IV. The rule was effective beginning June 17, 2020. The University began the process of determining which students would receive grants in May 2020 and checks were issued on June 29 and 30, 2020, thus the process of distributing funds was already in place when the Interim Final Rule was issued. Cause There were not adequate controls in place to ensure student eligibility was determined and documented before emergency aid grants were disbursed. Additionally, the University did not timely monitor the rapidly changing criteria set forth by the Department of Education. The Interim Final Rule published on June 17, 2020 was less than two weeks prior to the funds being disbursed to students, which made it difficult administratively to determine eligibility criteria. Effect The effect or possible effect is that students that were not considered eligible may have received funds. The Department of Education may request the school to pay back the funds that are used for ineligible purposes. The second round of HEERF funds provided under CRRSAA in 2021 does not require Title IV Eligibility. Recommendation The University should monitor requirements and eligibility criteria closely and frequently for COVID-19 related programs. The federal and state monies being awarded related to COVID-19 are changing constantly and may require consultation with subject matter experts. Auditee?s Response See attached corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2020-003 Year Affected June 30, 2020 Program COVID-19 CARES Act Higher Education Emergency Relief Funding (CFDA 84.425) Finding Type Compliance and Control Criteria Under the CARES Act passed on March 27, 2020, aid was granted to the University under the program Higher Education Emergency Relief Funding (HEERF). This aid was to be used at least 50% towards direct student emergency relief grants (student portion under 84.425E) and the remainder could be used towards institutional needs (84.425F). Both portions of the funds stipulated restrictive use for specific approved purposes. Emergency grants to students under 84.425E could only be provided to students that qualify under Title IV eligibility criteria. Condition The financial aid office was unable to provide documentation of Title IV eligibility for 8 students from the sample of 45 students. Questioned Costs Total questioned costs are estimated to be $37,719: $ 9,825 - 7 student findings $ 27,894 - 1 student finding extrapolated over a sub-population Context An Interim Final Rule was released on June 17, 2020 that required emergency grants to students be only to students eligible under Title IV. The rule was effective beginning June 17, 2020. The University began the process of determining which students would receive grants in May 2020 and checks were issued on June 29 and 30, 2020, thus the process of distributing funds was already in place when the Interim Final Rule was issued. Cause There were not adequate controls in place to ensure student eligibility was determined and documented before emergency aid grants were disbursed. Additionally, the University did not timely monitor the rapidly changing criteria set forth by the Department of Education. The Interim Final Rule published on June 17, 2020 was less than two weeks prior to the funds being disbursed to students, which made it difficult administratively to determine eligibility criteria. Effect The effect or possible effect is that students that were not considered eligible may have received funds. The Department of Education may request the school to pay back the funds that are used for ineligible purposes. The second round of HEERF funds provided under CRRSAA in 2021 does not require Title IV Eligibility. Recommendation The University should monitor requirements and eligibility criteria closely and frequently for COVID-19 related programs. The federal and state monies being awarded related to COVID-19 are changing constantly and may require consultation with subject matter experts. Auditee?s Response See attached corrective action plan.
Finding Number: 2020-003 Planned Corrective Action: Regarding the seven students who may have received emergency grants from the University without the University having in its possession evidence of Title IV eligibility, management acknowledges that it did not perform sufficient verification of all students on the list that it generated before emergency grants were issued and that it did not sufficiently monitor the multiple communications coming from the Department of Education which provided guidance on the grants. This was due to a lack of monitoring by the designated party. With the subsequent federal programs that have provided federal funding to the University, the University has more adequately developed its lists of student recipients in conformity with government guidance. Indeed, the University just made more than 200 emergency grants, and management is confident that all necessary precautions were observed. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin, CFO
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
FAC accepted this audit on October 22, 2018 — management decision was due April 22, 2019.
FAC accepted this audit on November 6, 2017 — management decision was due May 6, 2018.
FAC accepted this audit on November 28, 2016 — management decision was due May 28, 2017.
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