Trustees of Amherst College

2024-001 Enrollment reporting Sponsoring Agency: Department of Education Cluster: Student Financial Assistance Award Names: Pell Grant Program and Federal Direct Student Loans Award Number: Not applicable Award Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Criteria Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP). There are two categories of enrollment information, "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. (34 CFR 685.309) Additionally, when a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student 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; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). (34 CFR 685.309) Condition Through testing of 16 student enrollment status changes, we noted that 3 out of 16 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 10 days late. Cause The Institution utilizes the National Student Clearinghouse (NSC) to report status changes. The Institution does not provide status changes to NSC until first of term reporting following the add/drop period. Once the Institution sends changes to NSC, there is a lag between NSLDS receiving the enrollment status change data. As such, more than 60 days had elapsed before either a withdrawn or graduation status was reported to NSLDS. Effect The effective administration of Title IV loans could be impacted when changes in students' status are not reported timely and accurately. The accuracy of enrollment information is important as the student's enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Government's payment of interest subsidies. Questioned Costs None identified. Recommendation We recommend that the lag in timing of submission of date to NSC and ultimate transmittal to NSLDS is taken into consideration when a student withdraws at Amherst to ensure timely reporting in the future. Management’s Views and Corrective Action Plan Management's response is included in "Management’s Views and Corrective Action Plan included at the end of this report after the summary schedule of status of prior audit findings.

2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, the College procedures include (amongst other items) obtaining a Commitment Form from the subrecipient, performing an initial risk assessment on all subrecipients, and updating that risk assessment based on the Controller Office’s judgement. The College also annually reviews the subrecipient's Uniform Guidance (“UG”) report and performs any necessary follow-up to issue a management decision, where applicable. Condition Through our testing of 4 subrecipients, we noted the following: • For all samples, we were unable to obtain sufficient evidence of the College’s annual subrecipient risk assessment. • For all samples, we were unable to obtain sufficient evidence of the College’s annual review of the audited financial statements and UG report, documentation of their review of the subrecipient’s audit report, and actions taken as a result of the findings in the report. Cause The College indicated subrecipient reviews, including the annual risk assessment and review of the UG report, were performed informally by the Principal Investigators and financial staff and not consistently documented. The College cites insufficient staffing needed for the formal documentation of the subrecipient risk assessment and monitoring procedures as the cause. Effect The lack of an annual review of subrecipient UG reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the UG. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs None identified. Recommendation We recommend the College reassess the design of its controls around subrecipient risk assessment and monitoring during the ongoing monitoring process. The College should formalize the documentation and review of its controls related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings.

2022-001 Review of Return of Title IV Funds calculation Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Names: Federal Pell Grant Program, Federal Supplemental Educational Opportunity Grants, Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Numbers: 84.063, 84.007, 84.268 Criteria a) In accordance with 34 CFR section 668.22 (a) (1), when a recipient of the Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of the Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. b) Management has a process in place whereby the Return of Title IV aid calculations are prepared by Assistant Dean of Financial Aid and reviewed by Senior Associate Dean or Dean of Financial Aid. Condition We tested a sample of 5 students who were awarded Title IV aid and withdrew from the College during the fiscal year that required a Return of Title IV aid calculation. For each of the 5 calculations, management performed the calculation accurately, however, there was no evidence noting review and approval by the Senior Associate Dean or Dean of Financial Aid based on management?s process. Cause The College did not retain sufficient evidence of the review performed by management over the Return of Title IV aid calculations. Effect An inaccurate Return of Title IV aid calculation could result in the College returning excess Title IV aid to the Department of Education or disbursing excess Title IV aid to the student in excess of allowable amounts in an untimely manner. Questioned Costs None identified. Recommendation We recommend that the College retain sufficient evidence of the review performed by management over the Return of Title IV funds calculations to ensure that the refunds are accurate. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.

2022-002 Enrollment reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Number: 84.268 Criteria In accordance with 34 CFR 690.83(b)(2) and 685.309, institutions are required to report enrollment information under the Federal Pell Grant (?Pell?) and Federal Direct Loan (?Direct Loan?) programs through the National Student Loan Data System (?NSLDS?). The enrollment information, including Campus Level and Program Level data, must be reviewed, updated, and validated by the institution promptly. Furthermore, specific to the Direct Loan program, for a student that received a Direct Loan and was enrolled or accepted for enrollment at the institution, and the student had 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, the institution must report the change within 60 days from which the change was identified. Management has a review process in place over this compliance requirement. Condition We tested a sample of 25 students that had received either the Federal Pell Grant and/or Federal Direct Loans and had an enrollment status change at the College during the fiscal year. Of the 25 selections, we noted 1 instance in which the student?s withdrawn enrollment status, for a student who received only Federal Direct Loans, was not reported timely to the NSLDS and was not identified as part of management?s review process. The enrollment status change was reported by the College to NSLDS 195 days after the College was aware of the change in enrollment. Additionally, once the change in enrollment was reported to NSLDS by the College, the effective date of the student?s enrollment change per the student?s transcript did not agree to the NSLDS campus level and program level reporting. Cause The College noted the error occurred as a result of an oversight by the individual involved in processing the enrollment status of the student in Colleague, the student information system. The student?s course enrollment for the spring semester was appropriately marked as ?W? on 4/11/2022 when the leave was identified, however the ?Haitus? screen in Colleague was not updated to reflect the status change. Essentially the student withdrew from all courses, but as the ?Haitus? screen was not updated, the enrollment change did not get picked up in the College?s enrollment query for transmission to the NSLDS. Management identified the issue upon review and corrected the status type change and reported to the NSLDS. However, the individual inaccurately reported to the NSLDS an effective date as 5/20/2022, which did not agree to the effective date per the student file of 4/8/2022. Effect The effective administration of Title IV loans could be impacted when changes in students? status are not reported timely. The accuracy of enrollment information is important as the student?s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Department of Education?s payment of interest subsidies. Questioned Costs None identified. Recommendation We recommend the College ensure individuals involved in the process receive additional training over the system and/or business processes and policies to help ensure changes in enrollment information are accurately and timely reported to NSLDS. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.

2022-003 Education Stabilization Fund reporting Grantor: Department of Education Award Name: COVID-19 Education Stabilization Fund ? Student Aid Portion Award Year: July 1, 2021 ? June 30, 2022 Award Number: P425E204900 - 20B Assistance Listing Numbers: 84.425E Criteria In accordance with Coronavirus Response and Relief Supplemental Appropriations Act section 314(c)(1), (c)(3), and American Rescue Plan section 2003(5) and Pub. L. No. 117-2 (March 11, 2021), the entity is required to publicly post information no later than 30 days after the award and update that information every calendar quarter and post the report no later than 10 days after the end of each calendar quarter (i.e., Jan 10, April 10, July 10, and October 10). Condition We tested two of four quarterly report submissions that were required during the fiscal year for the student portion of funding received under the Higher Education Emergency Relief program. One of the submissions tested, the April 10th submission, was not submitted by the required deadline and was 14 days late. Cause The late reporting submission was an oversight as a result of turnover in the College?s Student Financial Aid department. Once the oversight was identified, the College filed the submission shortly thereafter. Effect The lack of timely and accurate reports could impact decision making of report users, including the Department of Education and the general public, among others. Questioned Costs None identified. Recommendation We recommend management establish automated reporting reminders that provide a notification to the individual submitting the report that the report is coming due. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.

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