ADELPHI UNIVERSITYHigher Education

Finding 2025-001 Reporting - Direct Loan and Pell Common Origination and Disbursement (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Award Year: 2024-2025 Criteria: Under the Federal Pell Grant program, institutions are required to report enrollment information via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify 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”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. When a Federal Loan is made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceases to be enrolled on at least a half- time basis or fails to enroll on at least a half-time basis for the period for which the loan is intended, or a student who is enrolled at the institution and who receives a loan under Title IV has changes 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). Enrollment information is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Context: Pursuant to Federal Register Volume 87, Number 105, an institution must submit Pell Grant Loan disbursement records to the Common Origination and Disbursement (“COD”) system no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV program funds are disbursed on the date that the institution credits a student’s account at the institution or pays a student or parent directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition: During our testing surrounding the University’s COD reporting process, the University did not report all Pell Grant disbursements to COD within the 15-day timeframe stipulated in Federal Register Volume 87, Number 105. Of the thirty-two (32) individual Pell Grant disbursements for seventeen (17) students selected for testing, we noted three (3) records that were not reported within the aforementioned 15-day timeframe. These three (3) Pell Grant records were reported between fifty-six (56) and one hundred thirty (130) days after the actual disbursement date. Cause: The condition was due to ineffective controls over the timeliness of COD reporting, including the absence of a formal monitoring process to track and ensure Pell disbursements were reported within required timeframes. In addition, processes and controls were not adequately updated to reflect the Department of Education’s temporary extension of reporting requirements, and late submissions were not timely identified and remediated through supervisory review. Effect: The University did not accurately report enrollment status for three (3) of the students tested within the required timeframe. Questioned Costs: None noted. Identified as a Repeat Finding: No. Recommendation: The University should review the effectiveness of its internal controls governing the timely submission of Pell Grant disbursements to ensure such records are submitted within the appropriate timeframe. Views of Responsible Officials and Planned Corrective Action: Management agrees with the findings and recommendations. The University has implemented corrective actions to prevent recurrence by transitioning Pell Grant processing to a fully automated system that interfaces directly with the COD system. This change is expected to reduce manual intervention, minimize errors, and improve compliance, with completion anticipated within 18 months and ongoing monitoring by Financial Aid and IT.

Finding 2024-001 – Subrecipient Monitoring (Significant Deficiency) U.S. Department of Health and Human Services Substance Abuse and Mental Health Service Projects (93.243) Federal Award Year: 2023-2024 Criteria and Context: Institutions are required to follow specific subrecipient monitoring requirements to ensure compliance with federal regulations. They must assess the risk level of subrecipients before awarding funds, carefully evaluating factors such as financial stability, prior audit findings, and overall capacity to manage federal funds. Once this evaluation is complete, institutions must establish formal agreements with subrecipients, clearly outlining compliance expectations, reporting requirements, and allowable costs. In addition to setting these agreements, institutions must engage in continuous monitoring efforts. This includes conducting financial reviews, obtaining OMB reports, performing site visits, and evaluating performance to ensure that funds are being used appropriately. If any issues arise during these monitoring activities, institutions must take corrective actions—whether by providing technical assistance, imposing additional funding conditions, or implementing other necessary measures to maintain compliance. Furthermore, institutions are responsible for maintaining thorough records of all subrecipient monitoring activities and must report any significant findings to federal agencies. By following these protocols, institutions help ensure that federal funds are properly managed and that subrecipients adhere to all necessary regulations. Condition: During our audit, we noted that the University was unable to provide sufficient documentation to demonstrate that it had performed the required ongoing monitoring of subrecipients during the audit period. The absence of such documentation indicates that the University did not fully comply with the federal requirements for subrecipient monitoring. Cause and Effect: During the award period, the personnel responsible tor conducting subrecipient monitoring procedures left the University. Following their departure, management was unable to obtain evidence confirming that the required compliance procedure had been performed during the period. Questioned Costs: None noted. Identified as a Repeat Finding: No Recommendation: The University should review and strengthen its policies and procedures related to subrecipient monitoring to ensure continuity and compliance throughout the entire award period. This includes assigning clear responsibilities, implementing cross-training for key personnel, and establishing documentation protocols to ensure that monitoring activities are consistently performed and retained, even during periods of staff transition. Views of Responsible Officials: Management acknowledges and agrees with the finding and recommendations. The University has addressed this issue by incorporating a procedure for subrecipient monitoring into their compliance checklist. As a result, monthly reminders will be sent to a designated group within the Finance team to help prevent recurrence.

Finding 2024-002 – Procurement, Suspension and Debarment (Significant Deficiency) U.S. Department of Health and Human Services Substance Abuse and Mental Health Service Projects (93.243) Federal Award Year: 2023-2024 Criteria and Context: Institutions are required to adhere to specific requirements for procurement and suspension and debarment to ensure compliance with federal regulations. In accordance with 2 CFR Part 200, procurement processes must promote full and open competition, requiring institutions to maintain written policies, prevent conflicts of interest, and implement cost-effective purchasing methods. When selecting vendors, institutions must assess qualifications, pricing, and past performance to ensure compliance. Contracts should clearly define expectations related to federal regulations. Additionally, before awarding contracts or subawards, institutions must confirm that vendors and subrecipients are not suspended or debarred from receiving federal funds, typically by verifying their status through SAM.gov. Thorough documentation of procurement activities—including vendor selection, contract terms, and suspension and debarment verifications—is essential. Institutions must also conduct regular reviews of procurement practices to ensure compliance with federal guidelines and take corrective actions if noncompliance is identified. These measures help safeguard federal funds and ensure partnerships with eligible vendors and subrecipients. Condition: The University had not established formal procedures to verify the suspension or debarment status of vendors and subrecipients prior to issuing contracts or subawards. Cause and Effect: During the award period, management had personnel turnover, resulting in operational disruptions and a loss of institutional knowledge. Consequently, newly assigned staff were unfamiliar with established procedures for verifying the suspension or debarment status of vendors and subrecipients. The lack of structured knowledge transfer and training contributed to inconsistent compliance practices and increased the risk of noncompliance with federal eligibility requirements. Questioned Costs: None noted. Identified as a Repeat Finding: No Recommendation: The University should review and update its policies related to suspension and debarment to ensure compliance with federal requirements. Specifically, procedures should be implemented requiring personnel to verify the eligibility of all vendors and subrecipients by confirming their status through the System for Award Management (SAM.gov) prior to the execution of any federally funded contracts or subawards. This verification should be documented and retained as part of the procurement and subaward process. Views of Responsible Officials: Management agrees with the findings and recommendations. The University has implemented corrective actions to prevent recurrence by establishing procedures that assess the eligibility of all vendors and subrecipients, confirming their status through the System for Award Management (SAM.gov) before executing any federally funded contracts or subawards. These procedures have been incorporated into the University’s compliance checklist, which is reviewed monthly to ensure adherence.

Criteria and Context: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify 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?) website. 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. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Under the Pell grant and Direct loan programs, institutions must complete and return within 30 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845-0002) mailboxes sent by ED via the NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). After the institution submits the Enrollment Reporting roster to NSLDS, NSDLS evaluates the Enrollment Reporting roster and provides the institution with an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS. Enrollment information is used to determine the borrower?s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Condition: The University has established procedures whereby it completes Enrollment Reporting roster files on a monthly basis and transmits such data to the NSLDS via the National Student Clearinghouse (?NSC?). Of the forty (40) students selected for enrollment reporting testing, we identified the following instances of noncompliance: ? For two (2) students, the incorrect Campus-Level enrollment status was reported to NSLDS after the date of determination of a Campus-Level enrollment change (i.e., the NSLDS submission immediately following the date the student was determined to have graduated, a status of full time was incorrectly reported instead). As there were errors in the submission that were not corrected within the appropriate timeframe, the submission was deemed late; and, therefore not in compliance with the aforementioned regulations. Cause, and Effect: In each of these instances, the student transferred between campuses at the University, which caused an overwriting error in the report submission. Questioned Costs: None noted. Identified as a Repeat Finding: No. Recommendation: The University should review its policies pertaining to enrollment reporting and implement changes to ensure that student status transmission reports are submitted timely and accurately to the NSLDS throughout the entire award year. Views of Responsible Officials: The status changes for these students were reported within the sixty day requirement (to the NSLDS, through the NSC). The unusual situation for these two students is that they both changed campus locations. We reported their enrollment in the manner instructed by the NSC, which is to report the student as withdrawn from one campus and enrolled at the other campus (enrollments are reported on separate files for each campus). When reviewing the reporting records, we can see that the correct data was transmitted to the NSC, and then subsequently by the NSC to the NSLDS, within the sixty day requirement. However, what we have learned now after investigating with the NSC, is that because the report indicating the withdrawal from one campus and the report indicating the enrollment at the other campus were filed on the same day, the data in essence overwrote each other. Error reports are received when data is rejected, but that was not technically the case in this situation (the records weren't actually rejected, they just overwrote each other) so these students did not appear on the error reports. We only learned of the error when the students graduated and their change in enrollment status from enrolled to graduated was rejected; the records appeared on the error report and were corrected at that point.