Brandeis UniversityHigher Education

Finding No. 2022-001 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education (DOE) Program: COVID-19 Education Stabilization Fund Under the Coronavirus Aid, Relief and Economic Security Act (CARES Act): ALN: 84.425F Criteria: Reporting requirements to the DOE state that the institutional portion of HEERF is reported by quarter in the quarter funds are drawn from the G5 system and reported for the allowable categories under the grant. The reports filed should include all information about expenditures incurred or lost revenues claimed under the grant. Condition: Amounts reported for the institutional portion by the University were originally reported in the incorrect period. Certain amounts were also reported in the wrong category (misclassified) or were omitted entirely ($137). Questioned Costs: None. Prevalence: 2 of 2 institutional quarterly reports tested. The sample was statistically valid. Effect: Incorrect amounts and classifications were reported to the DOE. Certain expenditures were also omitted. Improper reporting could result in the DOE withholding payments to the University. Cause: Changes to the program rules, regulations, and reporting for the HEERF programs were evolving throughout the different phases of the program. This issue is the result of improper tracking of those changes as they were occurring which resulted in errors in the original filing. The omission of certain costs was an oversight. The amount omitted was $137. Recommendation: We recommend the University amend the incorrect reports. The Federal funding for this program has ended. If the DOE should add additional funding or create new or similar programs, we recommend that management implement a control to regularly monitor and manage changes to rules and regulations promulgated by the DOE. View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding, and corrective measures have been made.

Finding No. 2021-001 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education (DOE) Program: COVID-19 Education Stabilization Fund Under the Coronavirus Aid, Relief and Economic Security Act (CARES Act) : ALN : 84.425F Criteria: Reporting requirements to the DOE state that the institutional portion of HEERF is reported by quarter and should not be cumulative. For reporting of HEERF II amounts, the University reported $2,999,232 and $4,452,457 for the periods ended March 31, 2021, and June 30, 2021, respectively. As the amounts should not be reported on a cumulative basis, the proper amounts should have been $2,853,225 and $0 for the periods ended March 31, 2021, and June 30, 2021, respectively. Condition: Amounts reported for the institutional portion by the University were originally reported at the cumulative amount, rather than the amount for the period as required. Questioned Costs: None. Context: See ?Condition? above. Effect: Incorrect amounts were reported to the DOE. Improper reporting could result in the DOE withholding payments to the University. Cause: In that the HEERF programs are newly created and did not exist prior to the passage of the CARES Act, the DOE has been issuing guidance related to the HEERF funding on an ongoing basis over a period of many months. Some guidance issued by DOE is issued and later modified or is non-existent until subsequent guidance is released. This issue is the result of confusion related to the filing requirements at the time of the original filing. Recommendation: We recommended to management prior to the end of the fiscal year that the University amend their reports to report only activity for the quarter. Management has amended these filings. We further recommend that management implement a control to regularly check the DOE website for changes or modifications which have the potential to impact compliance. View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding, and corrective measures have been made.

Finding No.: 2020-001 ? Enrollment Reporting Federal Agency: Department of Education Pass-through Agency: Direct Program Name: Student Financial Assistance Cluster ? Federal Direct Loan Program CFDA Numbers: 84.268 Federal Award Numbers: P268K200184 Federal Award Year: July 1, 2019 ? June 30, 2020 Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via National Student Loan Data System (NSLDS) within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that 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 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 Found Of the forty (40) students with enrollment changes selected for testwork, we noted thirty-eight (38) students whose changes in enrollment status were not accurately transmitted to NSLDS. The reporting to NSLDS for these students was transmitted with the status of withdrawn, when the enrollment status was graduated. Cause The University utilizes a third-party administrator, the National Student Loan Clearinghouse (NSLC), to transmit enrollment rosters and changes in enrollment status to NSLDS. Due to a coding error in the University?s reporting via the NSLC, the inaccurate enrollment status was transmitted (withdrawn versus graduated) to NSLDS. While the change in enrollment was transmitted timely, and did not have effect on the timing of students? loan repayments, the University?s review procedures did not identify that the incorrect status was reported to NSLDS. Possible Asserted Effect Inaccurate submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, as well as the federal government?s payment of interest subsidies. Questioned Costs No questioned costs identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This was not a finding in the prior year. Recommendation We recommend that the University review its processes to ensure that any enrollment changes are reported accurately within the required 30 or 60 day time frame when submitted to the NSLC. Additionally, a review of the submitted enrollment changes to the NSLC and NSLDS should be performed to ensure current student status is properly reflected. View of University Officials The University agrees with the finding and confirms that the issue had no impact on students' federal student loan repayment as they were reported as separated from the University in a timely manner. The University continues to review and improve business processes, including those performed by our thirdparty vendor, to ensure timely and accurate reporting to NSLDS. The University has submitted a corrected filing to NSLDS as a remedial effort.

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