SIMMONS UNIVERSITY

2022-001 Returns of Title IV Funds Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 Criteria 34 CFR 668.22(j): (1) An institution must return the amount of Title IV funds as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew (2) For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate; (ii) Academic year in which the student withdrew; or (iii) Educational program from which the student withdrew. Condition Through our testing of 16 students who were awarded Title IV aid and withdrew from the University, we noted the following: ? 2 instances where the student funds were not returned timely. More specifically, it was 52 days from when the 2 students withdrew from the University that the funds were returned and thus they were 7 days late. ? 6 instances where the Return of Title IV funds calculations were performed, but not subject to a second level of review and approval. Cause The University relies on PowerFaids to process the return of Title IV (R2T4) funds and has policies and procedures in place requiring a review of the calculation to be evidenced within PowerFaids. The University identified an issue in PowerFaids where the system was not identifying disbursements (and change of disbursements) for R2T4 students. Once the system issue was identified by management, they manually uploaded the R2T4 students to PowerFaids for disbursement to the federal government. However, the University did not have sufficient controls in place to ensure that the review of the Title IV return calculations were performed and the Title IV returns were issued timely. Effect The lack of timeliness or accuracy in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back to the federal government. Questioned Costs None identified. Recommendation We recommend that the University implement a control to monitor the processing and management of Title IV returns to ensure that the refunds are completed timely. 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 Borrower data and reconciliation reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 Criteria 34 CFR 685.300(b)(5): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to - On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition Through our testing of 3 Student Account Statement (SAS) reconciliations, we noted 1 instance where the SAS reconciliation was not performed. Cause The University did not have sufficient oversight over the personnel who was performing the SAS reconciliations from the summer leading up to the 2021-2022 academic year through March 2022. As a result, the September 2021 disbursements were not reconciled and the University did not have the appropriate controls in place to identify that the reconciliation was not performed. Effect Without the appropriate reconciliation of direct loan disbursements, the University has an increased risk that federal funding disbursed will not be effectively managed and expended in accordance with the terms and conditions of its agreement with the federal agency. Questioned Costs None identified. Recommendation We recommend that the University implement a second level of review to ensure that SAS reconciliations are prepared and reviewed on a timely basis. 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 Enrollment reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans, Federal Pell Grant Program Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Numbers: 84.268, 84.063 Criteria Federal regulations governing Title IV student aid programs require institutions, lenders, Government Agencies, and the Direct Loan Servicer to monitor and update the enrollment status of students who receive Federal student loans. Completion of Enrollment Reporting satisfies the regulatory requirements for schools. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (?NSLDS?). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (Direct Loan, 34 CFR section 685.309). The school remains responsible for submitting timely, accurate, and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with Federal Regulation 34 CFR 682.610(c). Condition Through our testing of 25 enrollment status changes, we noted the following: ? 9 instances where a student?s status was not reported timely to the National Student Clearinghouse (?NSC?). As the change in status was not reported in a timely manner to NSC by the University, that information was not transmitted to the NSLDS timely. As a result, it was between 129-238 days from when the status change was reported by the University to NSC to when NSLDS received the status change. ? 7 instances where the student?s change type per the student?s file did not agree to the NSLDS campus level reporting. ? 8 instances where the student?s change type per the student?s file did not agree to the NSLDS program level reporting. Cause The University implemented a new student information system, Workday Student, during FY22. The University relied upon Workday Student to upload the student status changes to NSC, which then sends the information to NSLDS. As a result of the system implementation, coding errors within Workday Student resulted in errors in the Degree Files, which prevented the NSC from processing the student status changes. The most common error related to students who had multiple branches on their enrollment record on NSC. NSC was not able to process which branch the ?Graduated? status should be applied to, leading to manual application of the status via the Error Report. The University was notified of the errors via email in the Error Report. However, due to turnover at the end of December 2021, those Error Reports were not received by the secondary employee who assumed the role. The issue was identified by management in August 2022 and coordinated with Workday Student specialists to remediate the issue. However, they did not have sufficient personnel due to turnover to identify and remediate the issue timely. Additionally, the University did not have sufficient controls in place to monitor that student status changes are communicated to NSC timely. 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 the University implement a control to ensure the completeness and accuracy of the information that is transmitted from Workday Student to the NSC and ultimately 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.

2020-001 Enrollment Reporting Cluster: Student Financial Assistance Agency: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2019 ? June 30, 2020 CFDA Number: 84.268 Criteria Federal regulations governing Title IV student aid programs require institutions, lenders, Government Agencies, and the Direct Loan Servicer to monitor and update the enrollment status of students who receive Federal student loans. Completion of Enrollment Reporting satisfies the regulatory requirements for schools. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (?NSLDS?). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (Direct Loan, 34 CFR section 685.309). The school remains responsible for submitting timely, accurate, and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with Federal Regulation 34 CFR 682.610(c). Condition Through our testing of 25 enrollment status changes, we noted one instance where a student?s status was not reported to the NSLDS in a timely fashion by the National Student Clearinghouse (?NSC?). While the change in status was reported in a timely manner to NSC by the University, that information was not then transmitted to the NSLDS timely. As a result, it was 179 days from when the status change was reported by the University to NSC to when NSLDS received the status change. Management identified one other instance of this through internal review after the identification of this exception. Cause The University placed reliance on NSC to report this information to NSLDS and did not have a sufficient internal review process in place to ensure that it was reported timely. 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 a student's enrollment status determines eligibility for 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 the University institute a control to ensure the completeness and accuracy of the information that is transmitted from the NSC to the NSLDS. Management?s Views and Corrective Action Plan Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.

2019-001 Cash Management Cluster: Research and Development Cluster Agency: U.S. Department of Health and Human Services, Institute for Museum and Library Services Award Name: IMLS ? National Leadership Grants, Beth Israel Deaconess Medical Center - Cancer Cause & Prevention Research Award Year: July 1, 2018 ? June 30, 2019 CFDA Number: 45.312, 93.393 Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition Through our testing of 25 grant expenditures, we noted 2 instances where the University paid a vendor subsequent to submitting the related federal reimbursement request. The first instance was a payment of $2,082, made 15 days subsequent to the related federal reimbursement request. The second instance was a payment of $79, made 33 days subsequent to the related federal reimbursement request. Cause Management requests reimbursement of federal funds on a monthly or quarterly basis and the reimbursement request includes all expenses for the previous month or quarter as applicable. There is a reconciliation completed to ensure the costs being requested have been recorded by the University prior to submitting the reimbursement request; however, the report is on an accrual basis that reflects the date of expense, rather than a cash basis that reflects the date of payment. Management assumes that vendors will be paid within 30-45 days, on average, after receipt of the invoice by the University. Effect Requesting drawdowns of federal funds prior to University payment of invoices can result in the federal government advancing funds to the University, which could result in interest being owed back to the government. Questioned Costs None identified. Recommendation We recommend that the University implement a control to ensure that management reviews whether an expenditure has been paid by the University prior to initiating the request for Federal reimbursement. Management?s Views and Corrective Action Plan Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.

2019-002 Procurement, Suspension and Debarment Cluster: Research and Development Cluster Agency: Institute for Museum and Library Services Award Name: IMLS - National Leadership Grants Award Year: July 1, 2018 ? June 30, 2019 CFDA Number: 45.312 Criteria In relation to procurement, suspension and debarment, the OMB Compliance Supplement states a non-Federal entity must use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). Additionally, Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition In testing the University?s conformity with the compliance requirements for procurement, we selected 2 Research and Development (?R&D?) procurements over the University?s defined micro-purchase threshold of $5,000 out of a population of 3 and noted that 2 selections did not have documentation of vendor quotations or a sole source justification prior to purchase. Additionally, we selected 3 R&D covered transactions for suspension/ debarment testing out of a population of 3 greater than the covered transaction threshold of $25,000 and noted that one selection did not have documentation of a suspension/debarment check being performed prior to entering into the transaction. This vendor was subsequently checked on the SAM database and found not to be suspended or debarred. Cause Under the University?s procurement policy effective as of July 1, 2018, vendor quotations or sole source justification are recommended (but not required) for purchases below $25,000. This is not aligned with the Uniform Guidance small purchase procedures. Additionally, the University does not have a process in place to ensure that suspension /debarment checks are performed for all covered transactions. Effect Items purchased with federal funds may be at increased risk for purchase at a higher rate if the University is not evaluating vendor quotations or properly documenting sole source justification. Additionally, not completing suspension and debarment checks presents the risk of the University engaging in procurement transactions with vendors who have been suspended or debarred. Questioned Costs None noted. Recommendation We recommend the University revise its procurement policies to align with the requirements of the Uniform Guidance. Management should implement a process whereby small purchase procedures or sole source justification documentation are required for review prior to approving the item for purchase (where applicable). Additionally, a control should be implemented to ensure that suspension/ debarment checks are performed and documented before entering into a covered transaction with a vendor. 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 status of prior audit findings and status.

2019-003 Documentation of review of subrecipient financial statements and risk assessment Cluster: Research and Development Cluster Agency: Institute for Museum and Library Services Award Name: IMLS ? National Leadership Grants Award Year: July 1, 2018 ? June 30, 2019 CFDA Number: 45.312 Criteria The OMB Compliance Supplement states that a non-Federal entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.331(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, onsite reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Condition In testing the University?s conformity with the compliance requirements for subrecipient monitoring, we selected 2 Research and Development (R&D) subrecipients out of a population of 3 and noted that while the University was able to demonstrate that the most recent financial statements, subrecipient invoices and progress reports were obtained, documentation of financial statement review and the completion of a subrecipient risk assessment was not maintained. Cause The University?s subrecipient monitoring policy requires review of subrecipient audited financial statements before contract inception and during the renewal process, but does not provide a formalized process to ensure that documentation of such review or of subrecipient risk assessments are maintained. Effect Without the appropriate level of documentation of ongoing monitoring of subrecipients, the University has an increased risk that federal funding disbursed to subrecipients will not be effectively managed and expended in accordance with the terms and conditions of its agreement with the federal agency. Questioned Costs None noted. Recommendation We recommend the University revise its subrecipient monitoring policies and implement a control to require formal documentation of subrecipient audited financial statement review. Additionally, we recommend that risk assessments performed on subrecipients be documented and the risk level assigned be reassessed and documented annually. 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 status of prior audit findings and status.

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