EIN: 221529785
UEI: J29MF78RN2M3
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 1, 2026 (38 days from today).
What is a management decision? →When students withdrew officially, the University did not always return unearned Title IV aid timely and accurately based on last date of attendance. Criteria: 34 CFR 668.22 Questioned Costs: $17,524 Context: Out of 9 students tested, 2 students who withdrew during the audit period tested did not have R2T4s completed resulting in late returns and 1 student had a R2T4 with incorrect last date of attendance resulting in an inaccurate return. The 2 students without a R2T4 should have had $10,927 and $6,284 in Federal Direct Loans returned. The 1 student with an inaccurate return should have had an additional $313 in Federal Direct Loans returned. Because of the error rate, this is classified as a material weakness. Cause: This was an oversight by the University and due to turnover in financial aid staff. Effect: R2T4s were not performed timely and incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University run a listing of withdrawals after each semester and compare the list of students who had R2T4s completed to ensure completeness. We further recommend a review of all R2T4s be performed to ensure they are completed accurately for the last date of attendance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Inaccurate and Untimely Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans Federal Award Identification #: 2024-2025 Financial Aid Year Condition: When students withdrew officially, the University did not always return unearned Title IV aid timely and accurately based on last date of attendance. Criteria: 34 CFR 668.22 Questioned Costs: $17,524 Context: Out of 9 students tested, 2 students who withdrew during the audit period tested did not have R2T4s completed resulting in late returns and 1 student had a R2T4 with incorrect last date of attendance resulting in an inaccurate return. The 2 students without a R2T4 should have had $10,927 and $6,284 in Federal Direct Loans returned. The 1 student with an inaccurate return should have had an additional $313 in Federal Direct Loans returned. Because of the error rate, this is classified as a material weakness. Cause: This was an oversight by the University and due to turnover in financial aid staff. Effect: R2T4s were not performed timely and incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University run a listing of withdrawals after each semester and compare the list of students who had R2T4s completed to ensure completeness. We further recommend a review of all R2T4s be performed to ensure they are completed accurately for the last date of attendance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: Saint Elizabeth University acknowledges this finding. The audit identified that 2 of 9 students who officially withdrew did not have Return of Title IV Funds (R2T4) calculations completed, resulting in late returns of $10,927 and $6,284 in Federal Direct Loans, and 1 student had an R2T4 prepared using an incorrect Last Date of Attendance (LDA), resulting in an additional $313 that should have been returned. Total questioned costs: $17,524. These errors were attributable to turnover in financial aid staff and the absence of a systematic withdrawal reconciliation process. The following corrective actions are being implemented in accordance with 34 CFR 668.22: Post-Semester Withdrawal Reconciliation: Following the end of each semester/payment period, the Financial Aid Office will generate a complete official withdrawal report from the student information system coordinating with the Registrar’s Office. This report will be compared against the R2T4 completion log to confirm that an R2T4 calculation has been performed for every student who officially withdrew during the period. R2T4 Timeliness Standards: SEU will adhere to the regulatory requirement that R2T4 calculations be completed no later than 30 days from the date of the institution's determination of withdrawal, and any required return of Title IV funds will be made to the Department no later than 45 days from the date of determination. Effective July 1, 2026, SEU will also implement the updated R2T4 regulations (GENERAL-26-20), including the requirement for attendance-taking institutions to document the withdrawal determination date no later than 14 days after the student's last date of attendance. Last Date of Attendance (LDA) Verification: Before finalizing any R2T4 calculation, the designated staff member will verify the LDA against all available attendance and/or activity documentation, including faculty attendance records, LMS login data, and any other institutional records. The Registrar’s Office will confirm the LDA used prior to calculation submission. R2T4 Accuracy Review: All completed R2T4 calculations will undergo a secondary review by the Director of Financial Aid or a senior FA staff member to verify accuracy prior to any return of funds to the Department. Staff Training: All financial aid staff involved in the R2T4 process will receive training on withdrawal procedures and R2T4 calculation requirements, including the updated regulations effective July 1, 2026, on an annual basis and whenever regulatory changes occur. Person Responsible: Tonya Williams, Director of Financial Aid Anticipated Completion Date: May 31, 2026 (remediation); ongoing thereafter
Students were not appropriately awarded subsidized loans based on need. Criteria: 34 CFR 685.200(a) and 34 CFR 685.102(b) Questioned Costs: $8,074 Context: Out of 60 students, 2 students were not awarded aid appropriately based on need analysis. The 2 students were awarded subsidized loans in excess of need of $5,063 and $3,011 based on scholarships and other aid set up in the system as excluded from other financial assistance. The students were not reallocated during the audit process. Cause: The University incorrectly set up scholarships as excluded from other financial assistance. Effect: Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University ensure that all scholarships are marked as other financial assistance and an awarding check is done accurately before disbursement is completed for the student. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Need Analysis Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans Federal Award Identification #: 2024-2025 Financial Aid Year Condition: Students were not appropriately awarded subsidized loans based on need. Criteria: 34 CFR 685.200(a) and 34 CFR 685.102(b) Questioned Costs: $8,074 Context: Out of 60 students, 2 students were not awarded aid appropriately based on need analysis. The 2 students were awarded subsidized loans in excess of need of $5,063 and $3,011 based on scholarships and other aid set up in the system as excluded from other financial assistance. The students were not reallocated during the audit process. Cause: The University incorrectly set up scholarships as excluded from other financial assistance. Effect: Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University ensure that all scholarships are marked as other financial assistance and an awarding check is done accurately before disbursement is completed for the student. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Planned Corrective Action: Saint Elizabeth University acknowledges this finding. The audit identified that 2 of 60 students were awarded subsidized Direct Loans in excess of demonstrated financial need — $5,063 and $3,011 respectively — because certain institutional scholarships were incorrectly coded in the financial aid system as excluded from Other Financial Assistance (OFA) rather than included. This caused the need calculation to be overstated, allowing subsidized loan awards that exceeded the students' actual calculated need. Total questioned costs: $8,074. The finding is classified as a Significant Deficiency under 34 CFR 685.200(a) and 34 CFR 685.102(b). The following corrective actions are being implemented: Scholarship Fund Code Audit: The Financial Aid Office will conduct a comprehensive review of all institutional scholarship and grant fund codes within the financial aid system to ensure that all institutional aid is properly flagged as Other Financial Assistance and is included in the need calculation prior to the application of the Subsidized loan. This review will be completed prior to the start of the 2026-2027 award year packaging process. Pre-Disbursement Awarding Check: A pre-disbursement review process will be implemented requiring a FA staff to confirm that all components of a student's financial aid package have been correctly categorized (OFA vs. non-OFA) and that subsidized loan awards do not exceed the student's calculated need, before disbursement is authorized. System Configuration Controls: SEU Information Technology (IT) will work with its financial aid system vendor to implement system-level controls that flag or prevent disbursement of subsidized loans when the need calculation indicates an award in excess of need, providing an additional automated safeguard. Annual Packaging Review: At the beginning of each award year, before packaging begins, the Director of Financial Aid will review and approve all fund code configurations in the financial aid system, documenting the review in writing and retaining it for audit purposes. Person Responsible: Tonya Williams, Director of Financial Aid Anticipated Completion Date: Review 2025-2026 students prior to year-end closeouts and packaging processes for the 2026-2027 award year.
The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 685.309 Questioned Costs: $0 Context: Out of 66 students tested, 8 students had not been reported accurately and timely. All 8 students were updated during the audit process. Cause: The University was not completing timely reconciliations of enrollment statuses throughout the year. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend that the University complete spot checks of NSLDS enrollment statuses throughout the year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans Federal Award Identification #: 2024-2025 Financial Aid Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 685.309 Questioned Costs: $0 Context: Out of 66 students tested, 8 students had not been reported accurately and timely. All 8 students were updated during the audit process. Cause: The University was not completing timely reconciliations of enrollment statuses throughout the year. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend that the University complete spot checks of NSLDS enrollment statuses throughout the year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Saint Elizabeth University acknowledges this finding. The audit identified that 8 of 66 students tested had enrollment statuses in NSLDS that were not reported accurately and timely, a result of SEU not completing consistent reconciliations of enrollment statuses throughout the year. All 8 students were updated during the audit process. Inaccurate or untimely NSLDS enrollment reporting can directly impact students' loan grace periods, in-school deferment eligibility, repayment start dates, and interest accrual, and constitutes noncompliance with 34 CFR 690.83(b) and 34 CFR 685.309. The following corrective actions are being implemented: Enrollment Reporting Schedule: SEU will establish and adhere to a formal enrollment reporting schedule aligned with NSLDS reporting requirements. Enrollment changes (including new enrollments, withdrawals, drops below half-time, graduations, and leaves of absence) will be submitted to NSLDS within 30 days of the roster file being sent by NSLDS, or within the timeframes required by the SAIG agreement. Roster File Reconciliation: Upon receipt of each NSLDS Roster File, staff in the Registrar's or Financial Aid Office will reconcile the enrollment statuses reported on the roster against current enrollment data in the student information system, and submit any required updates within the required reporting window. Periodic Spot Checks: In addition to responding to NSLDS Roster Files, SEU will conduct quarterly enrollment reconciliation spot checks, comparing NSLDS-reported statuses against the current enrollment records for a sample of enrolled, withdrawn, and graduated students. Results and any corrections made will be documented. Enrollment Status Triggers: SEU will establish automated or manual alert procedures for enrollment status changes that require NSLDS updates, including: semester-end enrollment confirmations, mid-semester withdrawals, grade-level changes, and program completions. Staff Training: Financial Aid and Registrar staff responsible for NSLDS reporting will receive training on the NSLDS Enrollment Reporting Guide (February 2026 version) requirements, including accurate use of enrollment status codes and reporting deadlines, on an annual basis. Person Responsible: Tonya Williams, Director of Financial Aid and Marybeth Obrycki, Registrar Anticipated Completion Date: June 30, 2026; ongoing quarterly thereafter
Underlying documentation for the FISAP reporting was not maintained. Therefore, the accuracy of certain key line items could not be tested. Criteria: 34 CFR 668.24(e) Questioned Costs: $0 Context: The University did not properly retain underlying support on the FISAP reporting for award year 2023-2024. Cause: This was an oversight by management. Effect: The University was unable to show evidence that they accurately reported items on the FISAP report. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University retain all data supporting all line items reported on the FISAP following the University's document retention policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴FISAP Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007 Federal Supplemental Opportunity Grant Program and 84.033 Federal Work Study Federal Award Identification #: 2024-2025 Financial Aid Year Condition: Underlying documentation for the FISAP reporting was not maintained. Therefore, the accuracy of certain key line items could not be tested. Criteria: 34 CFR 668.24(e) Questioned Costs: $0 Context: The University did not properly retain underlying support on the FISAP reporting for award year 2023-2024. Cause: This was an oversight by management. Effect: The University was unable to show evidence that they accurately reported items on the FISAP report. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University retain all data supporting all line items reported on the FISAP following the University's document retention policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
FISAP Reporting Planned Corrective Action: Saint Elizabeth University acknowledges this finding. The audit identified that SEU did not properly retain underlying documentation supporting the Fiscal Operations Report and Application to Participate (FISAP) submitted for award year 2023-2024, making it impossible to verify the accuracy of certain key line items. This constitutes noncompliance with 34 CFR 668.24(e), which requires institutions to maintain records supporting participation in Title IV programs for a minimum of three years following the end of the award year to which the records pertain. The following corrective actions are being implemented: FISAP Documentation Retention Procedure: SEU will implement a formal, written FISAP documentation retention procedure requiring that all data, reports, and supporting calculations used to complete each line item of the FISAP be compiled, labeled, and archived at the time of FISAP submission. Supporting documentation will include: Federal Work-Study payroll records, SEOG recipient lists with award amounts, Perkins Loan activity (where applicable), expenditure reports from the student financial aid system, and any other source documents used. Annual FISAP Preparation Checklist: The Financial Aid Office will use a standardized FISAP preparation checklist each year, with each line item cross-referenced to its source documentation. The completed checklist and all underlying support will be retained in a designated FISAP folder (electronic and/or physical) for each award year. Document Retention Compliance: All FISAP-related records will be retained for a minimum of three years following the end of the applicable award year (or longer if required by an ongoing audit, litigation, or other regulatory hold), in compliance with 34 CFR 668.24(e) and SEU's existing document retention policy. Pre-Submission Review: Prior to submission of each annual FISAP, the Director of Financial Aid or designee will review the completed FISAP against all supporting documentation to confirm accuracy, and will retain a copy of the submitted FISAP and all attachments. Post-Submission Audit File: Following FISAP submission, a complete audit file will be assembled containing the final submitted FISAP, confirmation of submission, and all supporting data. This file will be stored in a location accessible to the Financial Aid Director and available for auditor review. Person Responsible: Tonya Williams, Director of Financial Aid Anticipated Completion Date: Annual FISAP submission; documentation procedures effective immediately and all rules and regulations for reporting.
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University’s IT Department will work to update procedures and controls to ensure any federal regulations of the FTC Safeguards Rule (16 CFR § 314.4(b)(1) - 16 CFR § 314.4(i)) that were found to be in partial compliance are remediated and brought into compliance. Some of these have already been remediated. We will work with other departments who administer third party vendor accounts to enforce MFA where there are gaps. A penetration test and the standing up of a tool to continuously monitor our network internally and those of third party vendors are already in startup phases Our information security program and risk assessment will be updated to reflect any recommendations offered by our auditors to fill any existing gaps in the 2023 audit. Person Responsible for Corrective Action Plan: Ron Loneker, Jr., Director, IT Special Projects Anticipated Date of Completion: May 31, 2024
The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University’s IT Department will work to update procedures and controls to ensure any federal regulations of the FTC Safeguards Rule (16 CFR § 314.4(b)(1) - 16 CFR § 314.4(i)) that were found to be in partial compliance are remediated and brought into compliance. Some of these have already been remediated. We will work with other departments who administer third party vendor accounts to enforce MFA where there are gaps. A penetration test and the standing up of a tool to continuously monitor our network internally and those of third party vendors are already in startup phases Our information security program and risk assessment will be updated to reflect any recommendations offered by our auditors to fill any existing gaps in the 2023 audit. Person Responsible for Corrective Action Plan: Ron Loneker, Jr., Director, IT Special Projects Anticipated Date of Completion: May 31, 2024
The anticipated disbursement dates in COD were not updated with the actual dates of disbursement when reporting disbursement records for Federal Pell Grants (Pell) and Federal Direct Loans (FDL) to COD. Additionally two students did not have aid posted on their student accounts but it was reported to COD as disbursed. Criteria: 34CFR 668.164(a) Questioned Costs: $5,938 Context: 24 of the 55 tested had COD FDL disbursement date errors ranging from 24-25 days for a disbursement batch in March 2023. 1 of the 32 Pell students tested had a COD disbursement date error that was 108 days. 2 of the 55 tested had FDL disbursement amounts reported to COD incorrectly for disbursements not made on the student account. This resulted in incorrectly reporting $3,217 and $2,721 of Federal Direct Loan disbursements for each student, respectively. The University disbursed these amounts on the student accounts at a later date during the audit. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students’ accounts. Reconciliations of University records to COD were not completed regularly so the discrepancies between the two systems were not identified and corrected in a timely manner. Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates as well as the monitoring of FDL aggregate limits. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Common Origination and Disbursement (COD) Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The anticipated disbursement dates in COD were not updated with the actual dates of disbursement when reporting disbursement records for Federal Pell Grants (Pell) and Federal Direct Loans (FDL) to COD. Additionally two students did not have aid posted on their student accounts but it was reported to COD as disbursed. Criteria: 34CFR 668.164(a) Questioned Costs: $5,938 Context: 24 of the 55 tested had COD FDL disbursement date errors ranging from 24-25 days for a disbursement batch in March 2023. 1 of the 32 Pell students tested had a COD disbursement date error that was 108 days. 2 of the 55 tested had FDL disbursement amounts reported to COD incorrectly for disbursements not made on the student account. This resulted in incorrectly reporting $3,217 and $2,721 of Federal Direct Loan disbursements for each student, respectively. The University disbursed these amounts on the student accounts at a later date during the audit. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students’ accounts. Reconciliations of University records to COD were not completed regularly so the discrepancies between the two systems were not identified and corrected in a timely manner. Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates as well as the monitoring of FDL aggregate limits. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates reflect the actual disbursement date. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024
The anticipated disbursement dates in COD were not updated with the actual dates of disbursement when reporting disbursement records for Federal Pell Grants (Pell) and Federal Direct Loans (FDL) to COD. Additionally two students did not have aid posted on their student accounts but it was reported to COD as disbursed. Criteria: 34CFR 668.164(a) Questioned Costs: $5,938 Context: 24 of the 55 tested had COD FDL disbursement date errors ranging from 24-25 days for a disbursement batch in March 2023. 1 of the 32 Pell students tested had a COD disbursement date error that was 108 days. 2 of the 55 tested had FDL disbursement amounts reported to COD incorrectly for disbursements not made on the student account. This resulted in incorrectly reporting $3,217 and $2,721 of Federal Direct Loan disbursements for each student, respectively. The University disbursed these amounts on the student accounts at a later date during the audit. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students’ accounts. Reconciliations of University records to COD were not completed regularly so the discrepancies between the two systems were not identified and corrected in a timely manner. Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates as well as the monitoring of FDL aggregate limits. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Common Origination and Disbursement (COD) Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The anticipated disbursement dates in COD were not updated with the actual dates of disbursement when reporting disbursement records for Federal Pell Grants (Pell) and Federal Direct Loans (FDL) to COD. Additionally two students did not have aid posted on their student accounts but it was reported to COD as disbursed. Criteria: 34CFR 668.164(a) Questioned Costs: $5,938 Context: 24 of the 55 tested had COD FDL disbursement date errors ranging from 24-25 days for a disbursement batch in March 2023. 1 of the 32 Pell students tested had a COD disbursement date error that was 108 days. 2 of the 55 tested had FDL disbursement amounts reported to COD incorrectly for disbursements not made on the student account. This resulted in incorrectly reporting $3,217 and $2,721 of Federal Direct Loan disbursements for each student, respectively. The University disbursed these amounts on the student accounts at a later date during the audit. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students’ accounts. Reconciliations of University records to COD were not completed regularly so the discrepancies between the two systems were not identified and corrected in a timely manner. Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates as well as the monitoring of FDL aggregate limits. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates reflect the actual disbursement date. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024
The University did not properly evaluate a student as a potential unofficial withdrawal based on all F grades for the Spring 2023 term and did not process a return to Title IV (R2T4) calculation. Criteria: 34 CFR 668.22 Questioned Costs: $3,460 Context: From our disbursement sample, 1 out of 60 tested did not appear to have been properly evaluated as an unofficial withdrawal based on the student having all F grades for the Spring 2023 term. If the student’s attendance could not be determined for the term, then the University should have processed the return defaulting to 50%. The questioned costs reflect a R2T4 calculation that defaults to 50%. Cause: Staff turnover and management oversight. The University is to review students with Title IV aid and no passing grades 30 days after the end of each term to determine if the student unofficially stopped attending and unearned Title IV aid should be returned. Effect: Return of Title IV funds were not performed accurately or timely Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a zero credit report be run at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Unofficial Withdrawals Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 and 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not properly evaluate a student as a potential unofficial withdrawal based on all F grades for the Spring 2023 term and did not process a return to Title IV (R2T4) calculation. Criteria: 34 CFR 668.22 Questioned Costs: $3,460 Context: From our disbursement sample, 1 out of 60 tested did not appear to have been properly evaluated as an unofficial withdrawal based on the student having all F grades for the Spring 2023 term. If the student’s attendance could not be determined for the term, then the University should have processed the return defaulting to 50%. The questioned costs reflect a R2T4 calculation that defaults to 50%. Cause: Staff turnover and management oversight. The University is to review students with Title IV aid and no passing grades 30 days after the end of each term to determine if the student unofficially stopped attending and unearned Title IV aid should be returned. Effect: Return of Title IV funds were not performed accurately or timely Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a zero credit report be run at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Unofficial Withdrawals Planned Corrective Action: The University will run zero credit reports at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: June 30th, 2024
The University did not properly evaluate a student as a potential unofficial withdrawal based on all F grades for the Spring 2023 term and did not process a return to Title IV (R2T4) calculation. Criteria: 34 CFR 668.22 Questioned Costs: $3,460 Context: From our disbursement sample, 1 out of 60 tested did not appear to have been properly evaluated as an unofficial withdrawal based on the student having all F grades for the Spring 2023 term. If the student’s attendance could not be determined for the term, then the University should have processed the return defaulting to 50%. The questioned costs reflect a R2T4 calculation that defaults to 50%. Cause: Staff turnover and management oversight. The University is to review students with Title IV aid and no passing grades 30 days after the end of each term to determine if the student unofficially stopped attending and unearned Title IV aid should be returned. Effect: Return of Title IV funds were not performed accurately or timely Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a zero credit report be run at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Unofficial Withdrawals Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 and 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not properly evaluate a student as a potential unofficial withdrawal based on all F grades for the Spring 2023 term and did not process a return to Title IV (R2T4) calculation. Criteria: 34 CFR 668.22 Questioned Costs: $3,460 Context: From our disbursement sample, 1 out of 60 tested did not appear to have been properly evaluated as an unofficial withdrawal based on the student having all F grades for the Spring 2023 term. If the student’s attendance could not be determined for the term, then the University should have processed the return defaulting to 50%. The questioned costs reflect a R2T4 calculation that defaults to 50%. Cause: Staff turnover and management oversight. The University is to review students with Title IV aid and no passing grades 30 days after the end of each term to determine if the student unofficially stopped attending and unearned Title IV aid should be returned. Effect: Return of Title IV funds were not performed accurately or timely Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a zero credit report be run at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Unofficial Withdrawals Planned Corrective Action: The University will run zero credit reports at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: June 30th, 2024
The University did not adequately complete monthly reconciliations for Federal Direct Loans. Criteria: 34 CFR 685.300(b)(5) Questioned Costs: $0 Context: During the audit, it was determined that the University did not properly complete the mandatory monthly reconciliations for Federal Direct Loans. Cause: Staff turnover and management oversight. Effect: The University was not in compliance with the reconciliation requirements. Errors between disbursements reported to COD and actual disbursements to students’ accounts were not identified and corrected timely. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend that the University review the reconciliation requirements and properly complete the mandatory monthly reconciliations for Federal Direct Loans. The University should also review or refer to the U.S. Department of Education (ED) announcement DL-22-07 which included information to assist higher education institutions with the mandatory reconciliation requirements for the Federal Direct Loan Program. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Federal Direct Loans Reconciliations DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not adequately complete monthly reconciliations for Federal Direct Loans. Criteria: 34 CFR 685.300(b)(5) Questioned Costs: $0 Context: During the audit, it was determined that the University did not properly complete the mandatory monthly reconciliations for Federal Direct Loans. Cause: Staff turnover and management oversight. Effect: The University was not in compliance with the reconciliation requirements. Errors between disbursements reported to COD and actual disbursements to students’ accounts were not identified and corrected timely. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend that the University review the reconciliation requirements and properly complete the mandatory monthly reconciliations for Federal Direct Loans. The University should also review or refer to the U.S. Department of Education (ED) announcement DL-22-07 which included information to assist higher education institutions with the mandatory reconciliation requirements for the Federal Direct Loan Program. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Direct Loans Reconciliations Planned Corrective Action: The University’s Financial Aid Office will review the reconciliations to ensure that the Direct Loan Program is reconciled. We will also refer the ED announcement DL-22-07 to maintain consistent and accurate reconciliations. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024
2022-004
The University did not adequately complete monthly reconciliations for Federal Direct Loans. Criteria: 34 CFR 685.300(b)(5) Questioned Costs: $0 Context: During the audit, it was determined that the University did not properly complete the mandatory monthly reconciliations for Federal Direct Loans. Cause: Staff turnover and management oversight. Effect: The University was not in compliance with the reconciliation requirements. Errors between disbursements reported to COD and actual disbursements to students’ accounts were not identified and corrected timely. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend that the University review the reconciliation requirements and properly complete the mandatory monthly reconciliations for Federal Direct Loans. The University should also review or refer to the U.S. Department of Education (ED) announcement DL-22-07 which included information to assist higher education institutions with the mandatory reconciliation requirements for the Federal Direct Loan Program. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Federal Direct Loans Reconciliations DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not adequately complete monthly reconciliations for Federal Direct Loans. Criteria: 34 CFR 685.300(b)(5) Questioned Costs: $0 Context: During the audit, it was determined that the University did not properly complete the mandatory monthly reconciliations for Federal Direct Loans. Cause: Staff turnover and management oversight. Effect: The University was not in compliance with the reconciliation requirements. Errors between disbursements reported to COD and actual disbursements to students’ accounts were not identified and corrected timely. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend that the University review the reconciliation requirements and properly complete the mandatory monthly reconciliations for Federal Direct Loans. The University should also review or refer to the U.S. Department of Education (ED) announcement DL-22-07 which included information to assist higher education institutions with the mandatory reconciliation requirements for the Federal Direct Loan Program. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Direct Loans Reconciliations Planned Corrective Action: The University’s Financial Aid Office will review the reconciliations to ensure that the Direct Loan Program is reconciled. We will also refer the ED announcement DL-22-07 to maintain consistent and accurate reconciliations. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024
2022-004
The University did not adequately minimize the time between expenditures and drawdowns. Criteria: 34 CFR 668.162 Questioned Costs: $0 Context: During our audit, we noted the University had a refundable advance of approximately $269,000 as of July 1, 2022. The University made additional drawdowns totaling approximately $299,000 through September 30, 2022. The University did not have expenditures meeting this total amount of drawdowns until March 2023. Cause: Management oversight Effect: Noncompliance with cash management requirements Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that the University implement and follow a formal process for making drawdowns when or after expenditures have been incurred and require that supporting documentation be retained to support compliance with cash management requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Title V Grant Cash Management DEPARTMENT OF EDUCATION ALN #: 84.031S Federal Award Identification #: P031S200171 Condition: The University did not adequately minimize the time between expenditures and drawdowns. Criteria: 34 CFR 668.162 Questioned Costs: $0 Context: During our audit, we noted the University had a refundable advance of approximately $269,000 as of July 1, 2022. The University made additional drawdowns totaling approximately $299,000 through September 30, 2022. The University did not have expenditures meeting this total amount of drawdowns until March 2023. Cause: Management oversight Effect: Noncompliance with cash management requirements Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that the University implement and follow a formal process for making drawdowns when or after expenditures have been incurred and require that supporting documentation be retained to support compliance with cash management requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Title V Grant Cash Management Planned Corrective Action: The University will implement and follow a formal process for making drawdowns when or after expenditures have been incurred and require that supporting documentation be retained to support compliance with cash management requirements. Person Responsible for Corrective Action Plan: Jim Pierce, Controller Anticipated Date of Completion: June 30th, 2024
The University did not adequately minimize the time between expenditures and drawdowns. Criteria: 34 CFR 668.162 Questioned Costs: $0 Context: During our audit, we noted the University had a refundable advance of approximately $269,000 as of July 1, 2022. The University made additional drawdowns totaling approximately $299,000 through September 30, 2022. The University did not have expenditures meeting this total amount of drawdowns until March 2023. Cause: Management oversight Effect: Noncompliance with cash management requirements Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that the University implement and follow a formal process for making drawdowns when or after expenditures have been incurred and require that supporting documentation be retained to support compliance with cash management requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Title V Grant Cash Management DEPARTMENT OF EDUCATION ALN #: 84.031S Federal Award Identification #: P031S200171 Condition: The University did not adequately minimize the time between expenditures and drawdowns. Criteria: 34 CFR 668.162 Questioned Costs: $0 Context: During our audit, we noted the University had a refundable advance of approximately $269,000 as of July 1, 2022. The University made additional drawdowns totaling approximately $299,000 through September 30, 2022. The University did not have expenditures meeting this total amount of drawdowns until March 2023. Cause: Management oversight Effect: Noncompliance with cash management requirements Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that the University implement and follow a formal process for making drawdowns when or after expenditures have been incurred and require that supporting documentation be retained to support compliance with cash management requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Title V Grant Cash Management Planned Corrective Action: The University will implement and follow a formal process for making drawdowns when or after expenditures have been incurred and require that supporting documentation be retained to support compliance with cash management requirements. Person Responsible for Corrective Action Plan: Jim Pierce, Controller Anticipated Date of Completion: June 30th, 2024
The University does not have a purchasing or competitive bid policy that follows the federal regulations. The University did not follow its policy and federal procurement requirements when making purchasing and vendor decisions with Title V grant funds. Criteria: 2 CFR 200.318 through 200.327 Questioned Costs: $0 Context: While the expenditures tested as part of the audit met allowable cost and allowable activities requirements, the University did not follow its competitive bid policy nor were minimum federal procurement requirements followed properly. Cause: University personnel were unfamiliar with the federal procurement requirements. Effect: Noncompliance with procurement requirements that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University update their policies that follow the federal procurement requirements and the University implement procedures and controls to help prevent deviations from the policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Title V Grant Procurement DEPARTMENT OF EDUCATION ALN #: 84.031S Federal Award Identification #: P031S200171 Condition: The University does not have a purchasing or competitive bid policy that follows the federal regulations. The University did not follow its policy and federal procurement requirements when making purchasing and vendor decisions with Title V grant funds. Criteria: 2 CFR 200.318 through 200.327 Questioned Costs: $0 Context: While the expenditures tested as part of the audit met allowable cost and allowable activities requirements, the University did not follow its competitive bid policy nor were minimum federal procurement requirements followed properly. Cause: University personnel were unfamiliar with the federal procurement requirements. Effect: Noncompliance with procurement requirements that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University update their policies that follow the federal procurement requirements and the University implement procedures and controls to help prevent deviations from the policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Title V Grant Procurement Planned Corrective Action: The University will update and implement internal policies such that they align with the federal procurement requirements. Person Responsible for Corrective Action Plan: Jim Gerrish, Director of Facilities Anticipated Date of Completion: April 30, 2024
The University does not have a purchasing or competitive bid policy that follows the federal regulations. The University did not follow its policy and federal procurement requirements when making purchasing and vendor decisions with Title V grant funds. Criteria: 2 CFR 200.318 through 200.327 Questioned Costs: $0 Context: While the expenditures tested as part of the audit met allowable cost and allowable activities requirements, the University did not follow its competitive bid policy nor were minimum federal procurement requirements followed properly. Cause: University personnel were unfamiliar with the federal procurement requirements. Effect: Noncompliance with procurement requirements that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University update their policies that follow the federal procurement requirements and the University implement procedures and controls to help prevent deviations from the policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Title V Grant Procurement DEPARTMENT OF EDUCATION ALN #: 84.031S Federal Award Identification #: P031S200171 Condition: The University does not have a purchasing or competitive bid policy that follows the federal regulations. The University did not follow its policy and federal procurement requirements when making purchasing and vendor decisions with Title V grant funds. Criteria: 2 CFR 200.318 through 200.327 Questioned Costs: $0 Context: While the expenditures tested as part of the audit met allowable cost and allowable activities requirements, the University did not follow its competitive bid policy nor were minimum federal procurement requirements followed properly. Cause: University personnel were unfamiliar with the federal procurement requirements. Effect: Noncompliance with procurement requirements that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University update their policies that follow the federal procurement requirements and the University implement procedures and controls to help prevent deviations from the policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Title V Grant Procurement Planned Corrective Action: The University will update and implement internal policies such that they align with the federal procurement requirements. Person Responsible for Corrective Action Plan: Jim Gerrish, Director of Facilities Anticipated Date of Completion: April 30, 2024
FAC accepted this audit on April 21, 2023 — management decision was due October 21, 2023.
The University was not adequately assessing satisfactory academic progress (SAP) which resulted in financial aid being awarded to ineligible students as they did not have SAP appeals on file. Criteria: 34 CFR 668.34(c) Questioned Costs: $17,473 Context: 2 students out of 60 tested were awarded federal aid but were ineligible due to not meeting SAP requirements and did not have an approved appeal to reinstate eligibility. The University believes these students would have been granted an approved appeal had they completed the official appeal form. Cause: Management oversight. Turnover in staffing. Effect: There is a potential for students to have received federal aid that were not eligible and did not have a formal appeal submitted. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University only provide federal aid to those students who were not meeting SAP who had an approved appeal documented. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Satisfactory Academic Progress Appeals Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University was not adequately assessing satisfactory academic progress (SAP) which resulted in financial aid being awarded to ineligible students as they did not have SAP appeals on file. Criteria: 34 CFR 668.34(c) Questioned Costs: $17,473 Context: 2 students out of 60 tested were awarded federal aid but were ineligible due to not meeting SAP requirements and did not have an approved appeal to reinstate eligibility. The University believes these students would have been granted an approved appeal had they completed the official appeal form. Cause: Management oversight. Turnover in staffing. Effect: There is a potential for students to have received federal aid that were not eligible and did not have a formal appeal submitted. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University only provide federal aid to those students who were not meeting SAP who had an approved appeal documented. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Appeals Planned Corrective Action: The University will review SAP appeals for 2021-2022 to ensure that the appropriate documentation is received, and approval is documented. Additional actions that will be taken to prevent future occurrences are as follows: 1. Periodic review of SAP students to ensure that appropriate documents are obtained 2. Email students to inform them that the SAP has been approved or denied. Person Responsible for Corrective Action Plan: Sheri Jefferson, Interim Director of Financial Aid Anticipated Date of Completion: June 30, 2023
The University did not adequately complete monthly reconciliations for Federal Direct Loans. Criteria: 34 CFR 685.300(b)(5) Questioned Costs: $0 Context: During the audit, it was determined that the University did not properly complete the mandatory monthly reconciliations for Federal Direct Loans. Cause: Staff turnover and management oversight. Effect: The University was not in compliance with the reconciliation requirements. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University review the reconciliation requirements and properly complete the mandatory monthly reconciliations for Federal Direct Loans. The University should also review or refer to the U.S. Department of Education (ED) announcement DL-22-07 which included information to assist higher education institutions with the mandatory reconciliation requirements for the Federal Direct Loan Program. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Federal Direct Loans Reconciliations DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loans Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University did not adequately complete monthly reconciliations for Federal Direct Loans. Criteria: 34 CFR 685.300(b)(5) Questioned Costs: $0 Context: During the audit, it was determined that the University did not properly complete the mandatory monthly reconciliations for Federal Direct Loans. Cause: Staff turnover and management oversight. Effect: The University was not in compliance with the reconciliation requirements. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University review the reconciliation requirements and properly complete the mandatory monthly reconciliations for Federal Direct Loans. The University should also review or refer to the U.S. Department of Education (ED) announcement DL-22-07 which included information to assist higher education institutions with the mandatory reconciliation requirements for the Federal Direct Loan Program. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Direct Loans Reconciliations Planned Corrective Action: The University will ensure that incomplete reconciliation is completed for 2021-2022. We will ensure that monthly reconciliation is completed as required as follows: 1. Monthly reconciliations will be signed by the Director of Financial Aid and Vice President for Enrollment Management Person Responsible for Corrective Action Plan: Sheri Jefferson, Interim Director of Financial Aid Anticipated Date of Completion: June 30, 2023
While the University reported the HEERF student emergency grants disbursed each quarter, the HEERF institutional quarterly reporting was not completed and posted to the University?s website. Criteria: 2 CFR 200.329, 86 FR 26213 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Questioned Costs: $0 Context: During the audit, it was noted that the University did not complete the HEERF quarterly reporting requirements and make available on their website as listed in their grant agreements for the institutional and minority serving institution portions of their HEERF funding. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-005 Recommendation: We recommend that the University complete the HEERF quarterly reporting and make this available on their website until they no longer need to based on compliance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Higher Education Stabilization Fund (HEERF) Reporting DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: 2021-22 Financial Aid Year Condition: While the University reported the HEERF student emergency grants disbursed each quarter, the HEERF institutional quarterly reporting was not completed and posted to the University?s website. Criteria: 2 CFR 200.329, 86 FR 26213 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Questioned Costs: $0 Context: During the audit, it was noted that the University did not complete the HEERF quarterly reporting requirements and make available on their website as listed in their grant agreements for the institutional and minority serving institution portions of their HEERF funding. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-005 Recommendation: We recommend that the University complete the HEERF quarterly reporting and make this available on their website until they no longer need to based on compliance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund (HEERF) Reporting Planned Corrective Action: The University will work to provide additional staff training on HEERF quarterly reporting and will also work with staff in the communications department to ensure that all necessary HEERF institutional expenditure information is reported on the website. Person Responsible for Corrective Action Plan: Aaron Aska, EVP for Finance and Administration Anticipated Date of Completion: June 30, 2023
2021-005
FAC accepted this audit on June 28, 2022 — management decision was due December 28, 2022.
Students were not appropriately awarded subsidized loans based on need. Criteria: 34 CFR 685.200(a) Questioned Costs: $0 ? just reallocations between subsidized loans and unsubsidized loans. Context: Out of 60 students, 4 students were not awarded aid appropriately based on need analysis. All 4 students had a miscalculated need analysis resulting in subsidized loans being over allocated for a total of $18,840. Cause: The University incorrectly set up need-based aid parameters and calculations in the student information system. Effect: Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University correct the student information system to properly identify and calculate the need-based aid and work with the system vendor as necessary to set up the system to properly flag over awarding scenarios. We also recommend the University to implement a periodic review of need analysis to check for over or under awarding of need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Need Analysis and Estimated Financial Assistance Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Direct Student Loans Federal Award Identification #: 2020-2021 Financial Aid Year Condition: Students were not appropriately awarded subsidized loans based on need. Criteria: 34 CFR 685.200(a) Questioned Costs: $0 ? just reallocations between subsidized loans and unsubsidized loans. Context: Out of 60 students, 4 students were not awarded aid appropriately based on need analysis. All 4 students had a miscalculated need analysis resulting in subsidized loans being over allocated for a total of $18,840. Cause: The University incorrectly set up need-based aid parameters and calculations in the student information system. Effect: Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University correct the student information system to properly identify and calculate the need-based aid and work with the system vendor as necessary to set up the system to properly flag over awarding scenarios. We also recommend the University to implement a periodic review of need analysis to check for over or under awarding of need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-003 Need Analysis and Estimated Financial Assistance Planned Corrective Action: Saint Elizabeth University has already addressed this issue by making changes in staffing and setting up safeguards in our financial aid software system, PowerFAIDS. The new staff have been thoroughly trained to understand the need and how to calculate it; we have also set up safety features in the Packaging module of PowerFAIDS which does not allow financial aid administrators to add Direct Subsidized Loans if the student has already reached or exceeded their original need. If an administrator attempts to add need based aid to a student who is not eligible an error message will populate and the ineligible aid will automatically be removed. Person Responsible for Corrective Action Plan: Rebecca Rees, Director of Financial Aid Anticipated Date of Completion: July 1, 2022
The University did not reconcile HEERF expenditures and drew down approximately $224,000 of HEERF funds that were reimbursed by other sources. Criteria: 2 CFR 200 subpart E Questioned Costs: $0 Context: The error was identified as part of the audit when testing HEERF allowable costs. However, there are no questioned costs as the University has other allowable expenditures that can be allocated to HEERF for these funds. Cause: Turnover in staffing. A reconciliation of HEERF expenditures to draws from G5 was not completed. Effect: The University drew down funds for costs that weren?t allowable. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the University maintain a cumulative detail record of all costs charged to the HEERF funding and on a periodic basis, reconcile to grant funds drawn down to ensure compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Higher Education Stabilization Fund (HEERF) Allowable Costs Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.425F Federal Award Identification #: P425F200818 Condition: The University did not reconcile HEERF expenditures and drew down approximately $224,000 of HEERF funds that were reimbursed by other sources. Criteria: 2 CFR 200 subpart E Questioned Costs: $0 Context: The error was identified as part of the audit when testing HEERF allowable costs. However, there are no questioned costs as the University has other allowable expenditures that can be allocated to HEERF for these funds. Cause: Turnover in staffing. A reconciliation of HEERF expenditures to draws from G5 was not completed. Effect: The University drew down funds for costs that weren?t allowable. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the University maintain a cumulative detail record of all costs charged to the HEERF funding and on a periodic basis, reconcile to grant funds drawn down to ensure compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-004 HEERF Allowable Costs Planned Corrective Action: All proposed HEERF expenditures will be approved by the VP for Finance and Administration to ensure compliance with federal guidelines and reimbursement of such expenditures will be made on a timely basis. The G5 account balances and expenditures will be reconciled the G/L transactions and balances to ensure accuracy of accounting entries and related drawdowns. Person Responsible for Corrective Action Plan: Vincent Bilello, Controller Anticipated Date of Completion: July 1, 2022.
HEERF reporting was not always done accurately or timely. Criteria: 2 CFR 200.329, 86 FR 26213 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Questioned Costs: None Context: During the audit, it was noted that the University did not continue to update their website with the HEERF reporting requirements as listed in their grant agreements for the institutional and strengthening institutions portion. Only the quarter ending September 30, 2020 was reported. The HEERF Year 1 annual report submitted in February 2021, did not report the student aid emergency grants accurately. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2020-003 Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. We also recommend that all reporting be reviewed for accuracy and agree to underlying records. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Higher Education Stabilization Fund (HEERF) Reporting DEPARTMENT OF EDUCATION ALN #: 84.425E, 84.425F, 84.425L Federal Award Identification #: P425E200120, P425F200818, P425L200238 Condition: HEERF reporting was not always done accurately or timely. Criteria: 2 CFR 200.329, 86 FR 26213 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Questioned Costs: None Context: During the audit, it was noted that the University did not continue to update their website with the HEERF reporting requirements as listed in their grant agreements for the institutional and strengthening institutions portion. Only the quarter ending September 30, 2020 was reported. The HEERF Year 1 annual report submitted in February 2021, did not report the student aid emergency grants accurately. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2020-003 Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. We also recommend that all reporting be reviewed for accuracy and agree to underlying records. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-005 HEERF Reporting Planned Corrective Action: The Controller and Communications staff member will ensure that all HEERF information is reported on the website both accurately and timely. HEERF expenditures will be recorded in specific G/L accounts and supporting documentation will be reviewed and reconciled monthly to ensure accurate reporting. Also, see Corrective action Plan for Finding Number 2021-004. Person Responsible for Corrective Action Plan: Vincent Bilello, Controller Anticipated Date of Completion: July 1, 2022
2020-003
FAC accepted this audit on June 10, 2021 — management decision was due December 10, 2021.
Finding 2020-003 Higher Education Emergency Relief Funds Reporting Department of Education COVID 19-Higher Education Emergency Relief Funds-Student Aid Portion (CFDA # 84.425E) Criteria The Department of Education required institutions that received Higher Education Emergency Relief Funds 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after the award and update that information every 45 days. The information is required to be timely and accurate. Condition We noted that certain information required to be posted on the College's website was not accurate. Cause This finding appears to be due to administrative oversights. Effect The effect of this finding is noncompliance with the U.S. Department of Education regulations. Questioned Costs - None Context There was one reporting requirement during the fiscal year in which the College had to post certain information regarding the Higher Education Emergency Relief Funds 18004(a)(1) Student Aid Portion award to the institution?s website. The total emergency financial grants awarded to students was not accurate as of the date of the public posting. Identification as a Repeat Finding - No Recommendation We recommend the College review and revise their Higher Education Emergency Relief Funds reporting procedures to ensure all information posted to the College's website is accurate. Views of Responsible Officials We concur with this finding and revised our policy and procedure to ensure that the HEERF reporting posted to the College's website is accurate. We have corrected the information posted to the website to reflect the accurate required information.
Show full finding ▾Hide full finding ▴Finding 2020-003 Higher Education Emergency Relief Funds Reporting Department of Education COVID 19-Higher Education Emergency Relief Funds-Student Aid Portion (CFDA # 84.425E) Criteria The Department of Education required institutions that received Higher Education Emergency Relief Funds 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after the award and update that information every 45 days. The information is required to be timely and accurate. Condition We noted that certain information required to be posted on the College's website was not accurate. Cause This finding appears to be due to administrative oversights. Effect The effect of this finding is noncompliance with the U.S. Department of Education regulations. Questioned Costs - None Context There was one reporting requirement during the fiscal year in which the College had to post certain information regarding the Higher Education Emergency Relief Funds 18004(a)(1) Student Aid Portion award to the institution?s website. The total emergency financial grants awarded to students was not accurate as of the date of the public posting. Identification as a Repeat Finding - No Recommendation We recommend the College review and revise their Higher Education Emergency Relief Funds reporting procedures to ensure all information posted to the College's website is accurate. Views of Responsible Officials We concur with this finding and revised our policy and procedure to ensure that the HEERF reporting posted to the College's website is accurate. We have corrected the information posted to the website to reflect the accurate required information.
Saint Elizabeth University (formerly known as College of Saint Elizabeth) respectfully submits the following corrective action plan for the fiscal year ending June 30, 2020. Finding 2020-003 Higher Education Emergency Relief Funds Reporting It was noted that certain information required to be posted on the College?s website was not accurate. Recommendation from CohnReznick We recommend the College review and revise their Higher Education Emergency Relief Funds reporting procedures to ensure all information posted to College?s website is accurate. Saint Elizabeth University Corrective Action Plan The University concurs with this recommendation We have revised our policy and procedure to ensure that the HEERF reporting posted to the University?s website is accurate. We have corrected the information posted to the website to reflect the accurate required information.
FAC accepted this audit on March 30, 2020 — management decision was due September 30, 2020.
Finding 2019-001 Federal Work-Study Program Timesheet Certification Federal Work-Study Program (CFDA # 84.033) Criteria According to the Federal Register (34 CFR 675.19 (b)(2)(i)) an institution must establish and maintain fiscal records that include a certification by the participating student?s supervisor that each student has worked and earned the amount being paid. The certification must include or be supported by for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day. Condition We noted 16 Federal Work-Study Program timesheets with incorrect dates signed by a participating student and certified by the participating student?s supervisor. Cause These findings appear to be due to administrative oversights. Effect The effect of this finding is noncompliance with the U.S. Department of Education regulations. Questioned Costs- Questioned costs for the Federal Work-Study Program timesheets with incorrect dates was $488.05. Context A total of 11 Federal Work-Study Program participants were included in the randomly selected sample out of a total Federal Work-Study Program population of 93. Our testing noted 3 students with Federal Work-Study Program timesheets that had been completed and certified with incorrect dates. Identification as a Repeat Finding ? No Recommendation We recommend the College review and revise Federal Work-Study Program payroll procedures to ensure Federal Work-Study Program timesheets are accurately completed by the participating student and correctly certified by the participating student?s supervisor. Views of Responsible Officials and Planned Corrective Actions We concur with this finding and revised our policy and procedure to ensure that timesheets are accurately completed by the participating student and correctly certified by the participating student?s supervisor, by implementing the use of CollegeTime. This software allows students to electronically sign in and out and requires a supervisor to approve the time prior to the student getting paid.
Show full finding ▾Hide full finding ▴Finding 2019-001 Federal Work-Study Program Timesheet Certification Federal Work-Study Program (CFDA # 84.033) Criteria According to the Federal Register (34 CFR 675.19 (b)(2)(i)) an institution must establish and maintain fiscal records that include a certification by the participating student?s supervisor that each student has worked and earned the amount being paid. The certification must include or be supported by for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day. Condition We noted 16 Federal Work-Study Program timesheets with incorrect dates signed by a participating student and certified by the participating student?s supervisor. Cause These findings appear to be due to administrative oversights. Effect The effect of this finding is noncompliance with the U.S. Department of Education regulations. Questioned Costs- Questioned costs for the Federal Work-Study Program timesheets with incorrect dates was $488.05. Context A total of 11 Federal Work-Study Program participants were included in the randomly selected sample out of a total Federal Work-Study Program population of 93. Our testing noted 3 students with Federal Work-Study Program timesheets that had been completed and certified with incorrect dates. Identification as a Repeat Finding ? No Recommendation We recommend the College review and revise Federal Work-Study Program payroll procedures to ensure Federal Work-Study Program timesheets are accurately completed by the participating student and correctly certified by the participating student?s supervisor. Views of Responsible Officials and Planned Corrective Actions We concur with this finding and revised our policy and procedure to ensure that timesheets are accurately completed by the participating student and correctly certified by the participating student?s supervisor, by implementing the use of CollegeTime. This software allows students to electronically sign in and out and requires a supervisor to approve the time prior to the student getting paid.
Item 2019-001 Federal Work-Study Program Timesheet Certification Federal Work-Study Program (CFDA # 84.033) Recommendation from CohnReznick We recommend the College review and revise Federal Work-Study Program payroll procedures to ensure Federal Work-Study Program timesheets are accurately completed by the participating student and correctly certified by the participating student?s supervisor. College of Saint Elizabeth Corrective Action Plan The College concurs with this recommendation. College of Saint Elizabeth has already revised its Policy and Procedure to ensure that timesheets are accurately completed by the participating student and correctly certified by the participating student?s supervisor, by implementing the use of CollegeTime. This software allows students to electronically sign in and out and requires a supervisor to approve the time prior to the student getting paid.
FAC accepted this audit on March 27, 2018 — management decision was due September 27, 2018.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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