Wellesley CollegeHigher Education

Of the forty (40) students with outstanding Perkins loans selected for testwork, we noted three (3) students that the College was not able to locate the original promissory note. Additionally, the College identified an additional six (6) students that they could not locate original promissory notes for a total of nine (9) students out of a total of 367 loans outstanding.

Findings and Questioned Costs Relating to Federal Awards Finding No.: 2022-001 ? Special Tests Federal Agency: Department of Education Pass-through Entity: Direct Federal Program: Student Financial Assistance Cluster ? Federal Direct Loan Program, Federal Pell Grant Program Federal AL Number: 84.268, 84.063 Federal Award Numbers: P268K201616, P063P191616 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirement: Special Tests, Enrollment Reporting Criteria or Requirement According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via the National Students 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. Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NLSDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Additionally, there are two categories of enrollment information within NSLDS, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. Further, in accordance with 2 CFR 200.303(a), non-federal entities 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 Found The College generally certifies its enrollment reports through rosters provided to the NSC. Of the sixty (60) students with enrollment changes we selected for test work, we noted that for six (6) students, the College was notified of the student?s status change and the change was not timely reported to NSLDS. The College did not report the status change until 75-88 days following notification of the change in status.Possible Cause and Effect The College?s internal control processes did not operate consistently to ensure that all enrollment status changes are submitted timely to NSLDS. Delayed submission of student enrollment status information affects the determination that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This finding is a repeat of a finding in the immediately prior audit and the prior year finding number was 2021-003. Recommendation We recommend that the College review its process to ensure that any enrollment changes are reported within the required 30 or 60 day time frame to NSLDS. The College should work with NSC as needed to ensure proper protocols of transmission to NSLDS occur. View of College Officials The College recognizes the importance of timely reporting related to student status changes with respect to federal requirements. The College has implemented a manual review procedure that will help to ensure all status changes are reported timely to NSLDS.

The College?s policy is to disburse the funds to the student account and then notify the student or parent in writing the date and amount of the disbursement; the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and the procedure and time by which the student or parent must notify the institution that she wishes to cancel the loan. Of the twenty-five (25) students selected for test work, we noted seven (7) students who were credited federal direct loans who were not notified in writing within the required seven days. The seven (7) students identified were notified within 15-45 days after the crediting the student?s account.

The College did not perform the required monthly reconciliations between the SAS data file and the College?s financial records for the period from July 1, 2020 to December 31, 2020. The College began performing the required reconciliations beginning with the month of January 2021 and continued through the end of the fiscal year.

The College generally certifies its enrollment reports through rosters provided to the NSC. Of the sixty (60) students with enrollment changes we selected for test work, we noted the following students whose changes in enrollment status were not timely transmitted to NSLDS. ? For three (3) students, the College was notified of the student?s change in status from full-time to graduated. The College did not report the status change to NSLDS. Additionally, for the three (3) students, the College did not report the program level and campus level reporting to NSLDS. ? For seven (7) students, the College was notified of the student?s status change and the change was not timely reported to NSLDS. The College did not report the status change until 61 to 83 days following notification of the change in status.

The College is required to report to COD the actual disbursement date, and of the sixty (60) students selected for test work who had Federal Pell grants, we noted fifty (50) students whose Federal Pell disbursement date reported to COD did not match the College?s records by one (1) to four (4) days. Additionally, of the sixty (60) students selected for test work who had Direct Loans, we noted four (4) students whose Direct Loan disbursement date reported to COD did not match the College?s records by one (1) to four (4) days. The College is on the Reimbursement method and submitted the disbursement records timely but not accurately for the fifty-four (54) students.

The College does not have a documented Direct Loan quality assurance system or related internal control processes.

The College?s policy is to disburse the funds to the student account and then notify the student, or parent, in writing the date and amount of the disbursement; the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Of the forty (40) students selected for test work, we noted 10 students who were credited federal direct loans who were not notified in writing within the required seven days. The 10 students identified were notified within 31-32 days after the crediting the student?s account.

The College did not perform the required reconciliations between the SAS data file and the College?s financial records for the period from July 1, 2019 through June 30, 2020.

The College generally certifies its enrollment reports through rosters provided to the NSC. Of the forty (40) students with enrollment changes we selected for test work, we noted the following students whose changes in enrollment status were not timely and/or accurately transmitted to NSLDS. ?For four (4) students, the College was notified of the student?s change in status from full-time to leave of absence; however, the status was incorrectly reported to NSLDS as withdrawn. ?For three (3) students, the College was notified of the student?s change in status from full-time to withdrawn. The College did not report the status change within the required timeframe to NSLDS. The status changes were reported between 87 to 228 days following notification of the change in status. ?For five (5) students, the College was notified of the student?s status change and the change was not accurately or timely reported to NSLDS. The College did not report the status change until 63 to 86 days following notification of the change in status. Additionally, although the five (5) students were leave of absence changes, all were reported to NSLDS incorrectly as withdrawn. ?For 12 students, the program level reporting to NSLDS did not agree to the College?s enrollment records or to the campus level report. Of the 12 students, nine (9) were graduated students and three (3) were leave of absence. However, all were incorrectly reported as withdrawn on the program level report.

The College submitted the initial FISAP on October 29, 2020 and submitted corrections on December 8, 2020, both within the required timeframe. In February 2021, the Department of Education requested that the FISAP be resubmitted for a third time as the reported information was not accurate for Part III, sections 28.1, 29.1, 30.1 and 30.2 for the Federal Perkins Loan Program. The final corrected FISAP was submitted on February 24, 2021.

The College is required to report to COD the actual disbursement date, and of the forty (40) students selected for test work who had Federal Pell, we noted four (4) students whose Federal Pell disbursement date reported to COD did not match the College?s records. The College is on the reimbursement method and submitted the disbursement records timely but not accurately for the four students.

Findings and Questioned Costs Relating to Federal Awards Finding No.: 2019-001 Program Information: Research and Development Cluster Federal Agency: National Aeronautics and Space Administration National Science Foundation National Institutes of Health CFDA Number: Various Federal Award Year: Various Compliance Requirement: Equipment and Real Property Management Condition or Requirement Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e), which require that property records must be maintained and include various information including, but not limited to: 2 CFR section 200.313(d) Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Exhibit IV WELLESLEY COLLEGE Schedule of Findings and Questioned Costs Year ended June 30, 2019 IV-7 DRAFT 3/11/2020 3:26 AM 056986M-1A 19 WellesleyCollege SACR.docx Condition Found The College does not have a formal procedure to tag equipment purchased with federal dollars and to update and maintain the listing of equipment purchased with federal funds with appropriate identifying information. The College did perform an inventory of all science equipment in anticipation of a major renovation of its science building but this inventory listing was not reconciled to the listing of federally funded equipment nor were appropriate tags or identifying information included on the science equipment listing. Possible Asserted Cause and Effect The College does not have the appropriate processes, procedures and internal controls in place to update and validate the equipment listing to include all the required elements including tagging equipment with appropriate identifying information and reconciling this listing to the overall equipment inventory listing and validation process. Identification of Questioned Costs None. Whether Sampling was Statistically Valid Our sample was not intended to be and was not a statistically valid sample. Repeat Finding No. Recommendation We recommend that the College review its current policies and procedures to ensure that equipment acquired under federal awards is appropriately tagged and identified as purchased with federal dollars and records are updated to and reconciled to inventory records ensure compliance with federal regulations. Management?s Response Management recognizes the importance of maintaining compliance with requirements over equipment purchased with Federal funds. The College will review and update its process and procedures related to equipment purchased under federal awards, and will implement an formalized identification/tagging and record keeping process that is validated through inventory process to ensure compliance with federal regulations.

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