Saint Peter's University and AffiliatesHigher Education

2025-001 – National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P25819; P268K251819; 2024-2025 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted 15 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2024-001. Recommendation: We recommend the University evaluate its procedures for sending enrollment information to the NSLDS, especially around graduated enrollment information. Views of responsible officials: There is no disagreement with the audit finding.

2025-002 – Suspension and Debarment Policy Federal Agency: U.S. Department of Education Federal Program Name: Developing Hispanic-Serving Institutions Program: Ensuring Success for the New Majority Student; Bienestar (Wellbeing) for All Assistance Listing Number: 84.031S Federal Award Identification Number and Year: P031S230321, P031S210125; 2024-2025 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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: The University did not consistently perform requirements for suspension and debarment as outlined in the Uniform Grant Guidance. Questioned Costs: None. Context: The University did not implement a formal, written policy and procedure that aligned with the Uniform Grant Guidance requirements for suspension and debarment. Cause: The University did not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for suspension and debarment until May of 2025. Effect: Suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2024-003. Auditors’ Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P24819; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • 6 students out of a sample of 40 students had an enrollment effective date in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 4 students out of a sample of 40 students had an enrollment status in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS. • 11 students out of a sample of 40 students tested had an enrollment status in the campus-level and program-level of NSLDS that did not adhere to the guidance on the effective date for students who withdraw between academic terms. • 5 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2023-002. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A242604; P063P23819; P033A242604; P268K241819; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $78,101 Context: During our testing, we all Title IV checks outstanding over 240 days were not returned to the Department of Education. Cause: The University did not have a process in place to return Title IV checks outstanding more than 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks outstanding more than 240 days be returned to the Department of Education. Repeat Finding: Yes, 2023-004. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: STEM - PODER Assistance Listing Number: 84.031C Federal Award Identification Number and Year: P031C210076-23; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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: The University did not consistently perform requirements for suspension and debarment as outlined in the Uniform Grant Guidance. Questioned Costs: None. Context: The University did not implement a formal, written policy and procedure that aligned with the Uniform Grant Guidance requirements for suspension and debarment. Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for suspension and debarment. Effect: Suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance. Repeat Finding: No. Auditors’ Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. The payment schedule takes into account the cost of attendance, the student’s estimated family contribution (EFC) and the enrollment status of the student. Condition: 1 of 40 students tested was under awarded and disbursed Pell grant funds. Questioned costs: $450. Context: An incorrect EFC was used to calculate the Pell award. Cause: The student made changes to their Free Application for Federal Student Aid (FASFA) and the University did not use the most updated version of the student’s FASFA. Effect: A student was under awarded and disbursed Pell funds. Repeat Finding: No. Recommendation: We recommend that the University establish a process to review changes and updates to a student’s FASFA prior to disbursing funds to ensure the most up to date and accurate information is being used for Pell awards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following:  2 students out of a sample of 40 students tested were reported to the NSLDS with the incorrect enrollment status on both the campus-level and program-level records in the NSLDS.  1 student out of a sample of 40 students had an enrollment effective date in the program-level records that did not match what was reflected in the University’s records and the campus-level record in the NSLDS.  8 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner.  2 students out of a sample of 40 students tested did not have their summer 2023 term enrollment information reported to both the campus-level and program-level records in the NSLDS. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2023-002 – NSLDS Reporting (Continued)  1 student out of a sample of 40 students tested did not have their summer 2023 term reported to the program-level records in the NSLDS. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to calculate the percentage of the payment period or period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition, the University did not use the correct date of withdrawal for the one student. Questioned costs: $67. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2023-003 – Return of Title IV (R2T4) Calculations (Continued) Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students tested. During the break, the student notified the University they would not return after the scheduled break and the date of notification was used as the withdrawal date, rather than the last date of attendance before the scheduled break. Cause: Management had a process in place for using the correct withdrawal date and number of days in the schedule break, but the process was not followed for the one student. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat Finding: No. Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the correct date of withdrawal. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it issued that check. Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial aid were outstanding more than 240 days. Questioned Costs: $11,438. Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which were not returned to the Department of Education. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2023-004 – Title IV Refund Checks (Continued) Cause: The University did not have a process in place to return Title IV refund checks outstanding over 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education. Repeat Finding: No. Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the finding.

Finding 2021-002: Procurement Information on the Federal Program: U.S. Department of Education, STEM Undergraduate Retention, Graduation and Empowerment (SURGE) (Assistance Listing # 84.031), FAIN #P031C160038-19 and P031C160038-20 (October, 1, 2016 ? September 30, 2021). Finding Type: Significant Deficiency Criteria: 2 CFR 215.43 states that all procurement transactions shall be conducted in a manner to provide, to the maximum extent practical, open and free competition. The recipient shall be alert to organizational conflict of interest as well as noncompetitive practices among contractors that may restrict or eliminate competition or otherwise restrain trade. Awards shall be made to the bidder or offer or whose bid or offer is responsive to the solicitation and is most advantageous to the recipient, price, quality, and other factors considered. Solicitations shall clearly set forth all requirements that the bidder or offeror shall fulfill in order for the bid or offer to be evaluated by the recipient. Any and all bids or offers may be rejected when it is in the recipient?s interest to do so. Management requires that quotes be obtained for all small purchases. Condition and Context: For three of fourteen transactions tested, the University did not maintain a record of having obtained quotes. The sample was not intended to be, and was not, a statistically valid sample. Cause: The University was unable to access the records of the quotes for the purchases in question. Effect or Potential Effect: Potential to purchase goods that are not at a fair and competitive price. Questioned Costs: None Recommendation: We recommend that University management maintain adequate records of bids and quotes in a centralized repository to ensure compliance with 2 CFR 215.43.

Finding 2021-003: Reporting Information on the Federal Programs: U.S. Department of Education, COVID-19 Higher Education Emergency Relief Fund (Assistance Listing # 84.425E, 84.425F, 84.425L), FAIN #P425E200224, P425F200806, P425L200272, P425E200224-20A, P425F200806-20A, and P425E200224-20B (April 20, 2020 ? January 17, 2022); U.S. Department of Treasury, COVID-19 Coronavirus Relief Fund (Assistance Listing # 21.019) Finding Type: Significant Deficiency Criteria: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards 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 awards. Condition and Context: During our testwork performed, we noted the University did not establish internal control procedures over reporting to include independent review and written documentation of approval for the federal program financial reports tested. For a total of seven reports tested (five Higher Education Emergency Relief Fund reports and two Coronavirus Relief Fund reports), four reports (two Higher Education Emergency Relief Fund reports and two Coronavirus Relief Fund reports) were not reviewed and approved prior to submission to the federal agency. The sample was not intended to be, and was not, a statistically valid sample. Also, the University was unable to provide underlying documentation which reconciled to the amounts publicly reported for the two aforementioned Higher Education Emergency Relief Fund reports. Cause: Due to the lack of a centralized grant reporting process, the University did not have individuals identified who were responsible for the preparation and review of grant reports for each funding source. Effect or Potential Effect: There is a risk of improper expenditures being reported and not detected or errors in the accuracy of the reporting in accordance with federal regulations. Questioned Costs: None Recommendation: We recommend the University strengthen its process and related internal controls over the review and approval of federal reports, which includes formal written documentation evidencing the review and approval of the report and centralizing the report review to an individual that possesses the appropriate qualifications to perform the control.

Finding 2021-004: Equipment & Real Property Information on the Federal Program: U.S. Department of Education, STEM Undergraduate Retention, Graduation and Empowerment (SURGE) (Assistance Listing # 84.031), FAIN #P031C160038-19 and P031C160038-20 (October, 1, 2016 ? September 30, 2021). Finding Type: Significant Deficiency Criteria: Under Uniform Guidance 2 CFR 200.313(d)(2), a physical inventory of property must be taken and the results reconciled with the property records at least once every two years. Condition and Context: During our testing, we noted that the most recent inventory of equipment purchased with grant funding was taken during the fiscal year ended June 30, 2019 and no inventory had been taken during the year ended June 30, 2021. Cause: The COVID-19 pandemic had a significant impact on the University. This included a transition to a remote learning environment from March 2020 through June 2021. Once staff and faculty returned to campus ahead of the 2021-2022 academic year, certain areas of the campus in which equipment was stored remained inaccessible to faculty and staff. There was also an open position among the team responsible for administration of this grant, which resulted in insufficient staff to perform the physical inventory. Effect or Potential Effect: A lack of timely inventory could result in stolen or misplaced assets going unidentified. Questioned Costs: None Recommendation: We recommend that the University implement a process and control to ensure an inventory count is performed at least once every two years and reconciled to the property records.

Finding 2021-005: Activities Allowed/Allowable Costs Information on the Federal Program: U.S. Department of Treasury, COVID-19 Coronavirus Relief Fund (Assistance Listing # 21.019) Finding Type: Significant Deficiency Criteria: An organization should have a strong system of internal control that includes review of general disbursements and payroll transactions for proper classification and allowability in accordance with the terms and conditions of the award agreements and federal regulations. Uniform Guidance section 200.430, paragraph (i) standards for documentation of personnel expenses requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; (ii) be incorporated into the official records of the non-federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100 percent of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the nonfederal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-federal entity?s written policy; (vi) comply with the established accounting policies and practices of the non-federal entity; (vii) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity; and (viii) budget estimates alone do not qualify as support for charges to federal awards but may be used for interim accounting purposes. Condition and Context: During our testing of ten non-payroll transactions, we noted the University did not maintain adequate documentation of approval for nine of ten non-payroll disbursements charged to the grant. During our testing of four payroll transactions, we also noted the University recorded amounts based on budgeted estimates rather than actual amounts for all four payroll transactions tested. For one of four payroll transactions tested, the University was unable to provide documentation to support the incurrence of expenditures as a direct result of the COVID-19 pandemic and in excess of pre-pandemic budgeted amounts, resulting in questioned costs totaling $14,756. For the remaining three transactions, the University was unable to provide time and effort documentation to quantify the amount to be charged to the grant and the amount charged to the grant exceeded expenditures based on estimated time and effort by $13,268. The sample was not intended to be, and was not, a statistically valid sample. Cause: Members of the University?s management met to discuss and evaluate the expenditures which were appropriate to charge to the grant and how to allocate them among the various funding sources providing funding for Coronavirus relief and other purposes which crossed multiple grant funding sources. However, no record was kept of the meetings and discussions held or approval of allowable expenditures for inclusion in the grant. Payroll costs charged to the grant were approximated for budgetary purposes which was utilized for reporting; however, a subsequent review of time and effort for the individuals allocated to the grant and evaluation of allowability of costs incurred was not performed, which resulted in improperly claiming costs to the grant. Effect or Potential Effect: Payroll expenses charged to the grant were unallowable and overstated by $28,024 based on a review of budgeted costs utilized versus actual costs incurred. Questioned Costs: $28,024 Recommendation: We recommend the University implement a process and related controls related to review and approval of expenditure for allowability in accordance with the terms of the grant award and federal regulations. Payroll amounts charged to the grant should be based on actual time and effort reported by the employee working on the grant rather than budgeted amounts and related documentation maintained by the University to support those amounts. The University should implement a review process over recording of expenditures, including review of time and effort for payroll transactions, for proper classification and allowability.