WESTERN NEW ENGLAND UNIVERSITYHigher Education

Finding Number: 2022-001 Federal Agency: United States Department of Education Pass-through Agency: Direct Program Name: Education Stabilization Fund (HEERF) ? Student Aid Portion Assistance Listing Number: 84.425E Federal Award Numbers: P425E200967-20A P425E200967-20B Federal Award Year: July 1, 2021 ? June 30, 2022 Criteria Beginning May 6, 2020, ED required institutions that received a HEERF 18004(a)(1) student aid portion award to publicly post certain information on their website no later than 30 days after award and update the information every 45 days thereafter (by posting a new report). On August 31, 2020, ED revised the announcement by decreasing the frequency of reporting after the initial 30-day reporting period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020 should instead post a report every calendar quarter, with the first quarter report due by October 10, 2020, and covering the period form their late 45-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, and III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31 June 30). Auditors should determine if an institution was both timely and accurate in publicly posting its Student Aid Portion Reports from May 6, 2020, onward and sample these public reports and reconcile the publicly reported amounts with underlying documentation to ensure accuracy. The critical information that was required to be posted on the institution?s website included: 1) Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter).2) Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 3) Item #5: The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 4) Item #6: The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Lastly, Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity 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 statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition Found During our testing of two quarterly reports submitted, we found the University reported an inaccurate number of students who received Emergency Financial Aid Grants to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. For the number of students reported, the University appears to have duplicated students that received grants under both the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. The University reported 3,559 and 2,588 students for the March 31, 2022 and September 30, 2021 quarterly reports, respectively. Documentation provided by the University indicates that there were 2,349 and 1,901 unique students that received grants under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms for the quarters ended March 31, 2022 and September 30, 2021, respectively. Cause The condition results from a combination of the fact that this relates to a federal program with evolving requirements during the period under audit and insufficient controls around the reporting of the number of students receiving grants. Possible Asserted Effect Failure to implement sufficient internal controls to ensure the accuracy of these quarterly reports in accordance with federal regulations resulted in the University?s program being noncompliant with federal statues, regulations and the terms and conditions of the federal awards. Questioned Costs None.Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend that the University enhance its process and controls to ensure reports are accurately prepared in accordance with the federal regulations. Views of Responsible Officials The University will correct the following quarterly reports: September 2021, December 2021, and March 2022 to reflect the number of students receiving HEERF student aid.

Finding No.: 2021-001 ? Enrollment Reporting Federal Agency: Department of Education Pass-through Agency: Direct Program Name: Student Financial Assistance Cluster ? Federal Direct Loan Program, Federal Pell Grant Program Assistance Listing Number: 84.268, 84.063 Federal Award Numbers: P268K210217, P063P200217 Federal Award Year: July 1, 2020 ? June 30, 2021 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. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days to ensure attendance changes for students are reported within 60 days of the change. 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. 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. These internal controls should be in compliance with the guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition Found During our audit we found three (3) of forty (40) students selected for testing whose changes in enrollment status were not timely transmitted to NSLDS. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). The University generally certifies its enrollment reports through rosters provided to the NSC. Cause The University utilizes a third-party administrator, the National Student Clearinghouse (NSC), to transmit enrollment rosters and changes in enrollment status as required by federal regulations to the National Student Loan Data System (NSLDS). The University reported a roster file to NSC on March 30, 2021, which included the 3 students selected in our sample. NSC received the University?s file, however, due to an abnormally long error resolution process the enrollment changes were not reported in a timely fashion. Further, we noted management?s internal controls are not designed at a level of precision to ensure all enrollment status changes are accurately and timely transmitted to NSLDS. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status information affects the determinations 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 No questioned costs identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This was a finding in the prior year. Recommendation We recommend that the University review its processes to ensure that all enrollment changes are reported as intended within the required 60 day time frame. The University should work with NSC as needed to ensure proper protocols of transmission to NSLDS occur. Additionally, a review of the submitted enrollment changes to the NSLDS should be performed to ensure current student status is properly reflected. View of University Officials The University agrees with the condition identified. The error resolution process at NSC was an anomaly for the University for the March 30, 2021 file. When enrollment rosters are submitted to NSC the files go through a back-and-forth resolution process between the University and NSC to adjust data elements before the file can be processed by NSC. It has been the University?s practice to resolve errors within 30 days. The error resolution process averaged six days for the period under audit. The University will continue to work closely with NSC and has updated the enrollment roster submission schedule to better align with NSC?s receipt schedule of roster files from NSLDS. NSC has assigned a Priority Analyst to assist with enrollment roster submissions to NSLDS moving forward. The University is confident that these improvements to the process will mitigate the likelihood of similar findings in the future

Finding No.: 2021-002 ? Suspension and Debarment Federal Agency: National Science Foundation Pass-through Agency: Direct Program Name: Research & Development Cluster Assistance Listing Number: 47.041 ? Engineering Grants Federal Award Number: 2018150 Federal Award Year: July 1, 2020 ? June 30, 2021 Criteria 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Lastly, Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity 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 statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition Found During our audit over suspension and debarment, one (1) covered transaction was identified for testwork and the University was unable to provide support that they verified the vendor was not suspended or debarred prior to entering into a covered transaction with the vendor. It was further noted from discussions with management that the University currently does not have internal control?s to verify compliance with the suspension and debarment federal regulations. Cause The University has not established and implemented effective internal controls that provide reasonable assurance that grant funds are not used for covered transactions with an entity that is suspended or debarred. Possible Asserted Effect While it was determined that the University is in compliance with suspension and debarment regulations, failure to implement sufficient internal controls to verify the University does not enter into covered transactions with parties that are suspended or debarment in accordance with federal regulations increases the risk that the University may have material noncompliance with these federal regulations. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend that the University implement internal controls to ensure compliance with the federal regulations related to suspension and debarment to ensure covered transactions are not entered into with parties that have been suspended or debarred. Views of Responsible Officials The University will establish and implement internal controls to include verifying federal grant funds are not utilized for covered transactions with entities that are suspended and debarred. These internal control procedures will include at a minimum: 1) Prior to entering into any covered transaction, the University will verify, and maintain appropriate supporting documentation of the verification, that the entity has not been suspended or debarred by checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) on the SAM.gov website. 2) A semi-annual review of entities, where the University has entered into a covered transaction, will be performed to verify entities are not suspended and debarred. Entities identified as being suspended and debarred will be inactivated by the University. 3) The University will provide education and guidance to all Principal Investigators related to the University?s suspension and debarment procedures.

Finding No.: 2020-001 ? Enrollment Reporting Federal Agency: Department of EducationPass-through Agency: DirectProgram Name: Student Financial Assistance Cluster ? Federal Direct LoanProgram, Federal Pell Grant ProgramCFDA Number: 84.268, 84.063Federal Award Numbers: P268K200217, P063P190217Federal Award Year: July 1, 2019 ? June 30, 2020 CriteriaAccording to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must completeand return the Enrollment Reporting roster file via National Student Loan Data System (NSLDS) within 15days of receipt. Enrollment information must be reported within 30 days whenever attendance changes forstudents, unless a roster will be submitted within 60 days. An institution must notify the Secretary ofEducation if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who wasenrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least ahalf-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended.Further, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-Federal entity ismanaging the Federal award in compliance with Federal statutes, regulations, and the terms and conditionsof the Federal award. These internal controls should be in compliance with the guidance in ?Standards forInternal Control in the Federal Government? issued by the Comptroller General of the United States or the?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of theTreadway Commission (COSO).Condition FoundDuring our audit we found four (4) of forty (40) students selected for testing whose changes in enrollmentstatus were not accurately and timely transmitted to NSLDS. The Department of Education lists severalcertification methods for enrollment reporting, including certifying directly through the NSLDS website,certifying through the NLSDS?s batch enrollment reporting process, or through certification of rostersprovided to the National Student Clearinghouse (NSC). The University generally certifies its enrollmentreports through rosters provided to the NSC. Additionally, the reporting to NSLDS for these students weretransmitted with the status of withdrawn, when the enrollment status was graduated. CauseThe University utilizes a third-party administrator, NSC, to transmit enrollment rosters and changes inenrollment status to NSLDS. The University reported a roster file to NSC in May 2020, which included thefour students selected in our sample. NSC received the University?s file, and as the students had more thanone credential within the file, NSC did not process student records for individuals receiving multiplecredentials and as a result did not transmit the students indicating they had graduated to NSLDS. TheUniversity was unaware of the rejected records that were not correctly marked as graduated from NSC,and therefore did not update the student?s information timely. In addition to the four students selected in oursample, 128 students of 982 in the May 2020 roster file also had more than one credential within the fileand were not reported to NSLDS within the required timeframe.Further, we noted management?s internal controls are not designed at a level of precision to ensure allenrollment status changes are accurately and timely transmitted to NSLDS.Possible Asserted EffectInaccurate and delayed submission of student enrollment status information affects the determinations thatlenders and servicers of student loans make related to in-school status, deferments, grace periods, andrepayment schedules, as well as the federal government's payment of interest subsidies.Questioned CostsNo questioned costs identified.Statistical SamplingThe sample was not intended to be, and was not, a statistically valid sample.Repeat FindingThis was not a finding in the prior year.RecommendationWe recommend that the University review its processes to ensure that all enrollment changes arereported as intended within the required 30 or 60 day time frame. The University should work with NSC asneeded to ensure proper protocols of transmission to NSLDS occur. Additionally, a review of the submittedenrollment changes to the NSLDS should be performed to ensure current student status is properlyreflected. View of University OfficialsThe University's practice is to check errors in all enrollment files transmitted to the NSC. With EnrollmentTransmissions there is a dedicated area for Error Correction. These errors are dealt with for everyenrollment file transmitted. We know now that there is no similar error section for Graduates Only DegreeTransmissions. The four students found in the audit showing as Withdrawn instead of Graduated did not have the ?G? applied because they received multiple credentials at the same time, a degree and at leastone certificate. NSC automatically does not apply a ?G? when students receive more than one credential atthe same time. These four records, along with 270 students submitted between February of 2019 andFebruary of 2020 who did not have a ?G? applied and whose information did not show correctly withNSLDS, were corrected in February and March 2021. Moving forward, the University will continue to sendGraduate Only Degree Verify files which provide important student detail such as credentials earned to beavailable for potential employers to see, and the University started sending graduate only Enrollment Filesin February 2021. This solves the problem that created the conflicts of G not being applied in theGraduates Only Degree Transmission files for students earning multiple credentials simultaneously. TheUniversity will also check the ?G Not Applied? tab in the future. Additionally, the Director of Financial Aid willensure that student status is properly reflected with NSLDS. The Office of the Registrar has incorporatedinto its office manual step-by-step instructions for all processes related to submitting Enrollment Files andGraduates Only Degree Verify files including how to resolve all errors and ?G Not Applied? situations. Webelieve the combination of these steps will mitigate the likelihood of similar findings in the future.