EIN: 231352630
UEI: XF3XM9642N96
Audit also covers EIN: 231352000 · unlinked EINs have no separate FAC filing
Audited by: PricewaterhouseCoopers, LLP
Cognizant agency: 84 [Department of Education]
View federal awards & risk assessment →
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 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 September 30, 2026 (32 days from today).
What is a management decision? →Criteria The Electronic Signatures in Global and National Commerce Act (“E-Sign Act” requires a school to obtain a student's voluntary consent to participate in electronic transactions. Condition Drexel University acquired Salus University at the end of FY2024. Given the separate control environments in place during FY2025, each University was treated as a separate population for testing. We examined 25 student records for each University and noted that no consents to participate in electronic transactions were obtained. Cause The Universities do not have a process in place that prompts students to voluntarily consent to participate in electronic transactions before the federal funds are disbursed to them. Effect A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Questioned Costs None noted. Recommendation We recommend the University establish a process that prompts students to voluntarily consent to participate in electronic transactions prior to students receiving federal student financial assistance. Management’s Views and Corrective Action Plan Following this finding is Management’s View and Corrective Action Plan.
Show full finding ▾Hide full finding ▴Criteria The Electronic Signatures in Global and National Commerce Act (“E-Sign Act” requires a school to obtain a student's voluntary consent to participate in electronic transactions. Condition Drexel University acquired Salus University at the end of FY2024. Given the separate control environments in place during FY2025, each University was treated as a separate population for testing. We examined 25 student records for each University and noted that no consents to participate in electronic transactions were obtained. Cause The Universities do not have a process in place that prompts students to voluntarily consent to participate in electronic transactions before the federal funds are disbursed to them. Effect A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Questioned Costs None noted. Recommendation We recommend the University establish a process that prompts students to voluntarily consent to participate in electronic transactions prior to students receiving federal student financial assistance. Management’s Views and Corrective Action Plan Following this finding is Management’s View and Corrective Action Plan.
Management agrees with this finding and s currently working to implement an electronic consent (e-Consent) process for students to ensure compliance and improve documentation of student consent for electronic communications related to financial aid.Two processes are being implemented to address this requirement: 1.Incoming Students:For new students, the e-Consent process will be incorporated into the confirmation section ofSlate (University incoming student CRM, Customer Relationship Mangement System). This willallow incoming students to review and complete the e-Consent electronically during theadmissions and enrollment confirmation process. 2.Continuing Students:For currently enrolled students, the e-Consent acknowledgment will be incorporated into theStudent Financial Obligation and Tuition Repayment Agreement (SFO). This ensures thatcontinuing students provide consent as part of the annual financial responsibility agreement process. In addition, information about the e-Consent policy will be published on the Drexel University website within the Terms and Conditions section so students have clear access to the policy and understand the requirements for electronic communication. These updates will ensure that students formally acknowledge and consent to electronic communications regarding financial aid and student account information, strengthening institutional compliance and internal controls. We anticipate having this in place for the start of the 26-27 academic year processing.
Criteria 34 CFR part 668 addresses timely return of Title IV funds (“R2T4” to the Department of Education. The regulation notes that returns of Title IV funds are required to be deposited or transferred into the Student Financial Aid account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Condition Drexel University acquired Salus University at the end of FY2024. Given the separate control environments in place during FY2025, each University was treated as a separate population for testing. We examined 25 student records for each University. For three of the five students selected for testing at Salus University, the Title IV funds were not returned within 45 days of the student’s withdrawal from the University. The funds were returned between 140 and 147 days after the student’s withdrawal date, with is 95- 102 days outside of the required 45-day window. Although the funds were not returned within the required timeframe, the appropriate amount of funds were returned to the Department of Education. Cause As Salus University records were closed out the FY2025 loan year and consolidated with Drexel University in FY2025, Salus University was not able to process the return of these funds timely. During the merger process, the U.S. Department of Education required that Salus University’s academic year for federal loans be closed out in order to complete the institutional consolidation. During this closed period, several students withdrew from the Summer term, which led to Salus University being unable to process the return of these funds timely. Questioned Costs The only questioned costs were interest on Title IV funds that were held by the University, which were inconsequential. Effect The University held funds which should have been returned to the Department of Education in a timely manner. Recommendation While we acknowledge the root cause of this finding was the merger of Salus University, we recommend the University continue to enhance the execution of the Title IV return process to ensure all students that withdraw from the University have their aid reviewed and returned in a timely manner. Views of responsible officials and planned corrective actions Following this finding is Management’s View and Corrective Action Plan.
Show full finding ▾Hide full finding ▴Criteria 34 CFR part 668 addresses timely return of Title IV funds (“R2T4” to the Department of Education. The regulation notes that returns of Title IV funds are required to be deposited or transferred into the Student Financial Aid account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Condition Drexel University acquired Salus University at the end of FY2024. Given the separate control environments in place during FY2025, each University was treated as a separate population for testing. We examined 25 student records for each University. For three of the five students selected for testing at Salus University, the Title IV funds were not returned within 45 days of the student’s withdrawal from the University. The funds were returned between 140 and 147 days after the student’s withdrawal date, with is 95- 102 days outside of the required 45-day window. Although the funds were not returned within the required timeframe, the appropriate amount of funds were returned to the Department of Education. Cause As Salus University records were closed out the FY2025 loan year and consolidated with Drexel University in FY2025, Salus University was not able to process the return of these funds timely. During the merger process, the U.S. Department of Education required that Salus University’s academic year for federal loans be closed out in order to complete the institutional consolidation. During this closed period, several students withdrew from the Summer term, which led to Salus University being unable to process the return of these funds timely. Questioned Costs The only questioned costs were interest on Title IV funds that were held by the University, which were inconsequential. Effect The University held funds which should have been returned to the Department of Education in a timely manner. Recommendation While we acknowledge the root cause of this finding was the merger of Salus University, we recommend the University continue to enhance the execution of the Title IV return process to ensure all students that withdraw from the University have their aid reviewed and returned in a timely manner. Views of responsible officials and planned corrective actions Following this finding is Management’s View and Corrective Action Plan.
Management agrees with this finding. During the merger process, the U.S. Department of Education required that Salus University’s academic year for federal loans be closed out in order to complete the institutional consolidation. During this closed period, several students withdrew from the Summer term, which made it difficult to complete the R2T4 process within the standard timeline. This situation was the result of the unique operational constraints associated with the merger and is considered an anomaly rather than a reflection of Salus and Drexel University’s standard procedures. Now that Salus University and Drexel University are fully consolidated, we do not anticipate this circumstance occurring again. Drexel University maintains a written R2T4 policy that includes established procedures, system edit checks, and clearly defined staff responsibilities. Financial Aid team members are fully trained on R2T4 requirements and are responsible for monitoring student withdrawals and completing R2T4 calculations within the required timeframes to ensure compliance with federal regulations.
Criteria Per National Student Loan Data System (NSLDS Enrollment Reporting Guide 1.4 – At a minimum, schools are required to certify enrollment for all those who are included on your roster file (and Title IV aid recipients at least every two months and within 15 days of the date that NSLDS sends a roster file to the school or its third-party service provider. In accordance with 34 CFR 685.309(b, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition Drexel University acquired Salus University at the end of FY2024. Given the separate control environments in place during FY2025, each University was treated as a separate population for testing. We examined 25 student records for each University Drexel University Of the 25 students selected for testing, three were reported to NSLDS more than 60 days after the student had left the University, ranging between 64 and 87 days. Additionally, the status change for one student was not accurately reported to NSLDS. The student was originally enrolled at half-time, then withdrew. Prior to reporting the withdrawal to NSLDS, the student re-enrolled as “less than half-time”. The student’s change to withdrawn was never reported to NSLDS. Salus University Of the 25 students selected for testing, graduation status for two were not reported to NSLDS. Cause The Financial Aid office was not aware of student enrollment changes entered by the University Registrar that occurred after the last report to the NSLDS. Effect For these students, the change in status was not reported timely or accurately, as defined in the criteria above. Additionally, loan deferment issues can arise for the graduated students as their status was not reported. Questioned Costs There are no questioned costs associated with this finding.Effect For these students, the change in status was not reported timely or accurately, as defined in the criteria above. Additionally, loan deferment issues can arise for the graduated students as their status was not reported. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the University enhance the review process for student enrollment changes occurring after reporting to NSLDS to ensure timely reporting of student status changes. Management’s Views and Corrective Action Plan Following these findings are management’s views and corrective action plan.
Show full finding ▾Hide full finding ▴Criteria Per National Student Loan Data System (NSLDS Enrollment Reporting Guide 1.4 – At a minimum, schools are required to certify enrollment for all those who are included on your roster file (and Title IV aid recipients at least every two months and within 15 days of the date that NSLDS sends a roster file to the school or its third-party service provider. In accordance with 34 CFR 685.309(b, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition Drexel University acquired Salus University at the end of FY2024. Given the separate control environments in place during FY2025, each University was treated as a separate population for testing. We examined 25 student records for each University Drexel University Of the 25 students selected for testing, three were reported to NSLDS more than 60 days after the student had left the University, ranging between 64 and 87 days. Additionally, the status change for one student was not accurately reported to NSLDS. The student was originally enrolled at half-time, then withdrew. Prior to reporting the withdrawal to NSLDS, the student re-enrolled as “less than half-time”. The student’s change to withdrawn was never reported to NSLDS. Salus University Of the 25 students selected for testing, graduation status for two were not reported to NSLDS. Cause The Financial Aid office was not aware of student enrollment changes entered by the University Registrar that occurred after the last report to the NSLDS. Effect For these students, the change in status was not reported timely or accurately, as defined in the criteria above. Additionally, loan deferment issues can arise for the graduated students as their status was not reported. Questioned Costs There are no questioned costs associated with this finding.Effect For these students, the change in status was not reported timely or accurately, as defined in the criteria above. Additionally, loan deferment issues can arise for the graduated students as their status was not reported. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the University enhance the review process for student enrollment changes occurring after reporting to NSLDS to ensure timely reporting of student status changes. Management’s Views and Corrective Action Plan Following these findings are management’s views and corrective action plan.
Management agrees with this finding. The Office of the University Registrar has reviewed the findings and has implemented the following processes to ensure greater accuracy of reporting student enrollment data to the NSLDS. 1.The following process has already been implemented from the findings of the audit. a.Any student enrollment record update that occurs past the point in time of the lastenrollment file submitted to the National Student Clearinghouse (NSC) will be manuallyreported when the student record is updated within the student database to ensure thedata is reported in a timely manner. i.NLSDS reporting will be spot checked for the update of the data submitted to theNSC to ensure they are reporting the data to NSLDS within the requiredtimeframe of Department of Education standards and practices. The Office of the University Registrar will work with our colleagues in theFinancial Aid Office to receive view access to the NSLDS reporting portal toexpedite the review of the updates.
Criteria Student disbursements are required to be reported in the COD system within 15 days of disbursing the federal funds to the student. Condition Drexel University acquired Salus University at the end of FY2024. Given the separate control environments in place during FY2025, each University was treated as a separate population for testing. We examined 25 student records for each University. Through our testing of 25 selections for Drexel University, we noted that one of the 25 selections was not reported to the COD within 15 calendar days of the disbursement to the student. The noted disbursement was reported 20 calendar days late. Cause This exception was caused due to the student not answering a question on the Free Application for Federal Student Aid (FAFSA) regarding the completion of high school status, which relates to Ability to Benefit (ATB) eligibility. As the question was unanswered, the Banner system used for student accounts was not able to timely report disbursements to the COD. Effect Disbursements to the selected student were not reported timely to the COD. Additionally, late reporting could cause issues in tracking of disbursements made to students. Questioned Costs None noted. Recommendation We recommend the University establish a process, such as a checklist to report disbursements on a more frequent basis to the COD, to ensure timely transmission and error identification within the disbursement reporting. Management’s Views and Corrective Action Plan Following these findings are management’s views and corrective action plan.
Show full finding ▾Hide full finding ▴Criteria Student disbursements are required to be reported in the COD system within 15 days of disbursing the federal funds to the student. Condition Drexel University acquired Salus University at the end of FY2024. Given the separate control environments in place during FY2025, each University was treated as a separate population for testing. We examined 25 student records for each University. Through our testing of 25 selections for Drexel University, we noted that one of the 25 selections was not reported to the COD within 15 calendar days of the disbursement to the student. The noted disbursement was reported 20 calendar days late. Cause This exception was caused due to the student not answering a question on the Free Application for Federal Student Aid (FAFSA) regarding the completion of high school status, which relates to Ability to Benefit (ATB) eligibility. As the question was unanswered, the Banner system used for student accounts was not able to timely report disbursements to the COD. Effect Disbursements to the selected student were not reported timely to the COD. Additionally, late reporting could cause issues in tracking of disbursements made to students. Questioned Costs None noted. Recommendation We recommend the University establish a process, such as a checklist to report disbursements on a more frequent basis to the COD, to ensure timely transmission and error identification within the disbursement reporting. Management’s Views and Corrective Action Plan Following these findings are management’s views and corrective action plan.
Management agrees with this finding. The instance in which a Pell Grant disbursement was not reported to the U.S. Department of Education Common Origination and Disbursement (COD) System within the required 15 calendar days was due to the student not answering the high school completion question on the Free Application for Federal Student Aid (FAFSA), which relates to Ability to Benefit (ATB) eligibility. To address this issue and prevent recurrence, we have implemented an additional control. We now identify students who have been awarded a Pell Grant but have not answered the FAFSA high school completion question. For these students, an ATB requirement is posted on RRAAREQ, which prevents the Pell Grant from disbursing until the FAFSA question has been resolved. This process change ensures that Pell Grant funds will not disburse until the FAFSA high school completion question is completed, allowing the Pell Grant record to successfully extract to COD within the required reporting timeframe. This system update corrects the condition identified in the audit finding and strengthens our internal controls to ensure compliance with federal reporting requirements.
FAC accepted this audit on December 17, 2024 — management decision was due June 17, 2025.
During the FY2024 Uniform Guidance audit, we noted that there were $1.2 million of funds from this program that had underlying transaction dates from FY2023. These expenditures were not reported on the FY2023 SEFA but rather were included in the FY2024 SEFA. The omission in the prior year did not result in a change to the major program determination for the 2023 or 2024 audits. Cause: In April 2023, Drexel received a subaward for the SNAP Cluster and a new active fund account was created in the accounting system to track expenses after the subaward was signed. This was set up as a new active award in the system, however there was already an existing advance fund account set up in pre-award status prior to the subaward being executed. The FY2023 expenditures were recorded in pre-award fund account and not the new active fund account. Management included the new active fund account in the population for FY2023 SEFA reporting which had no expenditures and excluded the pre-award fund account with the $1.2 million of charges. This accounting for the FY2023 expenditures was corrected in July 2023 (FY2024) but not in time for SEFA reporting purposes. Effect: FY2023 SEFA expenditures for the SNAP cluster were understated by $1.2 million. This amount has been reported in the FY2024 SEFA. Questioned Costs: None; Recommendation: Management should enhance the control in place to perform a more precise review of award status and other reconciling items when preparing and reviewing the SEFA reconciliation to the financial statements. Management's View and Corrective Action Plan: Management agrees with the finding. Refer to the Management Corrective Action Plan on page 81.
Show full finding ▾Hide full finding ▴Criteria: 2 CFR 200.510 (b) requires an entity to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements. The schedule must include the total Federal awards expended as determined in accordance with 2 CFR 200.502 (a), which states that determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Condition: During the FY2024 Uniform Guidance audit, we noted that there were $1.2 million of funds from this program that had underlying transaction dates from FY2023. These expenditures were not reported on the FY2023 SEFA but rather were included in the FY2024 SEFA. The omission in the prior year did not result in a change to the major program determination for the 2023 or 2024 audits. Cause: In April 2023, Drexel received a subaward for the SNAP Cluster and a new active fund account was created in the accounting system to track expenses after the subaward was signed. This was set up as a new active award in the system, however there was already an existing advance fund account set up in pre-award status prior to the subaward being executed. The FY2023 expenditures were recorded in pre-award fund account and not the new active fund account. Management included the new active fund account in the population for FY2023 SEFA reporting which had no expenditures and excluded the pre-award fund account with the $1.2 million of charges. This accounting for the FY2023 expenditures was corrected in July 2023 (FY2024) but not in time for SEFA reporting purposes. Effect: FY2023 SEFA expenditures for the SNAP cluster were understated by $1.2 million. This amount has been reported in the FY2024 SEFA. Questioned Costs: None; Recommendation: Management should enhance the control in place to perform a more precise review of award status and other reconciling items when preparing and reviewing the SEFA reconciliation to the financial statements. Management's View and Corrective Action Plan: Management agrees with the finding. Refer to the Management Corrective Action Plan on page 81.
A review and training of the award set up process is being conducted to ensure all team members in Office of Sponsored Programs (OSP) follow the correct procedures for moving an advance fund number into a fully executed award. Implementation of a new electronic research administration system, Novelution, is currently underway. Internal controls will be incorporated into this system to track advance awards and their conversion into fully executed awards. This control will improve tracking and communication via systems to avoid the duplication of fund numbers for the same award. On a quarterly basis, Research Accounting Services (RAS) will send reports of advance funds to OSP to follow up on the status. RAS is also incorporating additional reviews during the SEFA preparation process. They will review advance funds to check with OSP to see if the fully executed agreements have been received from the sponsor and if any updates are needed. Novelution will also be a more robust system that will provide full grants management for agreements in order to provide more transparency across central units that will minimize these types of errors from occurring in the future. This is expected to be completed prior to the close of FY2025.
A physical inventory of the research funded property must be conducted and the results must be reconciled with the property records at least once every two years. The last physical inventory was conducted in FY2022. Cause: Management did not perform the physical inventory in FY2023 or FY2024 of the research funded property due to timing constraints. Management’s process includes other procedures such as an internal fixed asset confirmation over equipment and real property, however such procedures are not comprehensive or at a sufficient level of detail to meet the compliance requirement. Effect: Not performing the physical inventory could result in an inaccurate record of assets purchased with federal funds. Questioned Costs: None; Reccomendation: Management should ensure the physical inventory is scheduled early in the two year cycle to ensure completeness within the required two year timeframe. Managements's View and Corrective Action Plan: Management agrees with the finding. Refer to the Management Corrective Action Plan on page 81.
Show full finding ▾Hide full finding ▴Criteria: 2 CFR 200.313 (d) contains equipment management requirements which include a physical inventory of research funded property and reconciliation with the property records at least once every two years. Condition: A physical inventory of the research funded property must be conducted and the results must be reconciled with the property records at least once every two years. The last physical inventory was conducted in FY2022. Cause: Management did not perform the physical inventory in FY2023 or FY2024 of the research funded property due to timing constraints. Management’s process includes other procedures such as an internal fixed asset confirmation over equipment and real property, however such procedures are not comprehensive or at a sufficient level of detail to meet the compliance requirement. Effect: Not performing the physical inventory could result in an inaccurate record of assets purchased with federal funds. Questioned Costs: None; Reccomendation: Management should ensure the physical inventory is scheduled early in the two year cycle to ensure completeness within the required two year timeframe. Managements's View and Corrective Action Plan: Management agrees with the finding. Refer to the Management Corrective Action Plan on page 81.
Management agrees with the recommendation and has already contracted with an asset appraiser to physically inventory the research funded assets. We are also planning to do a full physical inventory of all property in the Spring of 2026 as part of our Facilities and Administrative Rate proposal base year activities.This is expected to be completed prior to the close of FY2025.
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
FAC accepted this audit on March 31, 2022 — management decision was due October 1, 2022.
"Finding 2021-001: Eligibility
Show full finding ▾Hide full finding ▴"Finding 2021-001: Eligibility
"Finding 2021-001 Eligibility
2020-001
FAC accepted this audit on May 10, 2021 — management decision was due November 10, 2021.
"Finding 2020-001: Eligibility Grantor: Aids Activity Coordinating Office (AACO)Program: Grants to Provide Outpatient Early Intervention Services with Respect to HIV DiseaseCFDA Number: 93.914Title: Ambulatory/Outpatient Medical Care, Care Services Case ManagementAward#: H89HA00013Award Year: 7/1/19-6/30/20CriteriaPer the AACO/PA Dept. of Health Ryan White Part A/B-Payer of Last Resort Client Certification Form Instructions, "The HealthResources and Services Administration (HRSA) standards require service providers who receive Ryan White funding to screen clientsand collect supporting documentation to certify their eligibility for Ryan White-funded services based on HIV positive diagnosis,identity, residence, insurance status, and income. The standards further require recertification every 6 months to determine continuedeligibility." The certification form states under the 'Verification of Insurance' requirement, "Having insurance or other third-partycoverage does not deem a client ineligible for Ryan White. However, that coverage should service as primary in reimbursementof services as Ryan White is to serve as "Payer of Last Resort" for those services. Verification of eligibility shall remain inclient's file".ConditionFor 2 of a sample of 40 patient files selected for testing in fiscal year 2020, the patients were certified as eligible for Ryan Whitefunds, yet each patient's insurance did not meet the "Payer of Last Resort" requirement. The same condition was present inthe prior year finding 2019-002.CauseBoth patients were originally certified as eligible based on allowable insurance coverage (i.e. Government programs). However,at their most recent recertification, both patients' insurance change to coverage that did not qualify under the " Payer of LastResort" requirement. The patients informed case managers of the change in insurance, but recertification still occurred withoutproper verification of income.EffectAs a result of not recertifying upon each visit as required under the program, ineligible participants may improperly receiveservices under the Ryan White program.Questioned CostsThere were no questioned costs related to this finding because federal funds were not specifically reimbursed to theUniversity for the services provided to the inappropriately recertified patients.
Show full finding ▾Hide full finding ▴"Finding 2020-001: Eligibility Grantor: Aids Activity Coordinating Office (AACO)Program: Grants to Provide Outpatient Early Intervention Services with Respect to HIV DiseaseCFDA Number: 93.914Title: Ambulatory/Outpatient Medical Care, Care Services Case ManagementAward#: H89HA00013Award Year: 7/1/19-6/30/20CriteriaPer the AACO/PA Dept. of Health Ryan White Part A/B-Payer of Last Resort Client Certification Form Instructions, "The HealthResources and Services Administration (HRSA) standards require service providers who receive Ryan White funding to screen clientsand collect supporting documentation to certify their eligibility for Ryan White-funded services based on HIV positive diagnosis,identity, residence, insurance status, and income. The standards further require recertification every 6 months to determine continuedeligibility." The certification form states under the 'Verification of Insurance' requirement, "Having insurance or other third-partycoverage does not deem a client ineligible for Ryan White. However, that coverage should service as primary in reimbursementof services as Ryan White is to serve as "Payer of Last Resort" for those services. Verification of eligibility shall remain inclient's file".ConditionFor 2 of a sample of 40 patient files selected for testing in fiscal year 2020, the patients were certified as eligible for Ryan Whitefunds, yet each patient's insurance did not meet the "Payer of Last Resort" requirement. The same condition was present inthe prior year finding 2019-002.CauseBoth patients were originally certified as eligible based on allowable insurance coverage (i.e. Government programs). However,at their most recent recertification, both patients' insurance change to coverage that did not qualify under the " Payer of LastResort" requirement. The patients informed case managers of the change in insurance, but recertification still occurred withoutproper verification of income.EffectAs a result of not recertifying upon each visit as required under the program, ineligible participants may improperly receiveservices under the Ryan White program.Questioned CostsThere were no questioned costs related to this finding because federal funds were not specifically reimbursed to theUniversity for the services provided to the inappropriately recertified patients.
"Finding 2020-001 Eligibility Agency: Aids Activity Coordinating Office (AACO)CFDA #: 93.914Title: Ambulatory/Out-Patient Medical Care, Care Services Case ManagementAward #: H89HA00013Award Year: 7/1/19-6/30/2020Management's Response:Management agrees with the finding that 2 of the 40 patients that were certified as eligible for Ryan White funds did notmeet the "Payer of Last Resort" income requirement. The two patients were both previously Ryan White (RW) eligible due to havingMedicaid and or/Special Pharmaceutical Benefit Program (SPBP) coverage. The error was made due to the certifier notchecking their current insurance status. In the past year their insurance status had changed from Medicaid and SPBPto private insurance. There was no current proof of income or proof of income by proxy from Medicaid or SPBP.Corrective Action Plan:This has been a recurring finding and more rigorous actions are necessary to remediate the finding. Starting October 26, 2020,with oversight from Amy Althoff, Medical Director, these actions will include 1. A training/retraining of staff on a quarterly basisof the Ryan White Certification process to understand the requirements and consequences. 2. The Director of Case Management,will spend on supervisory session each month with individual staff members to review and monitor corrective implementationof the RW Certification process. 3. There will be more of a focus on accurate certification of non-case managed patients.4. Project review, to be completed by December 31, 2020, will have a dedicated task force to review all current patients and theirRyan White eligibility. All currently active patients and unassigned patients will be assigned to case managers which will use achecklist as verification tool to confirm all supporting documentation for Ryan White eligibility is in the patients chart.5. Request to establish a full-time equivalent position who can concurrently work with uninsured patients to get insuranceand determine Ryan White eligibility.
2019-002
FAC accepted this audit on January 9, 2020 — management decision was due July 9, 2020.
"Finding 2019-001: Return of Title IV FundsGrantor: Department of EducationProgram: Student Financial Assistance ClusterTitle: Federal Direct Student Loan ProgramAward Year: 7/1/18-6/30/19Criteria34 CFR part 668 addresses timely return of Title IV funds (""R2T4"") to the Department of Education. The regulations note that returnsof Title IV funds are required to be deposited or transferred into the Student Financial Aid account or electronic funds transfersinitiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determinesthat the student withdrew.ConditionFor 1 of the 25 students selected for testing the Title IV funds were not returned within 45 days of the student's withdrawal from theUniversity. The funds were returned 85 days after the student's withdrawal date, which is is 40 days outside the required 45 daywindow. Although the funds were not returned within the required timeframe, the appropriate amount of funds were returned tothe Department of Education.CauseManagement utilizes a weekly ""R2T4 report"", which lists all students that have withdrawn, transferred, or otherwise discontinuedcoursework, to identify students requiring an R2T4 calculation to determine if funds need to be returned. Once the R2T4 calculationand return of funds is complete, the Office of Financial Aid will update the student account information in Banner( system of recordfor student activity), indicating that the requirement has been completed. At this point, the student will no longer appear on theweekly R2T4 report. The student noted above was incorrectly updated as complete for the R2T4 process in Banner. Althoughthe R2T4 calculation had been completed and reviewed, the final return of funds had not yet been processed and reviewed. Therefore,this was considered an error in execution of the control. The student was not listed on the subsequent weeks ""R2T4 report"", whichled to the late return of funds.Questioned CostsThere were no questioned costs related to this finding as the student was eligible to receive Tile IV aid, and the appropriate amountof aid was returned to the Department of Education.EffectIf Management does not complete all requirements for the R2T4 process prior to updating a student account to complete, aidreturned to the Department of Education could be incorrect or not returned at all.RecommendationWe recommend the University continue to enhance the execution of the Title IV return process to ensure all students that withdrawfrom the University have their aid reviewed and returned in a timely manner. The student account information within Banner shouldnot be updated until all procedures, including the final return of funds to the Department of Education, are completed and reviewed."
Show full finding ▾Hide full finding ▴"Finding 2019-001: Return of Title IV FundsGrantor: Department of EducationProgram: Student Financial Assistance ClusterTitle: Federal Direct Student Loan ProgramAward Year: 7/1/18-6/30/19Criteria34 CFR part 668 addresses timely return of Title IV funds (""R2T4"") to the Department of Education. The regulations note that returnsof Title IV funds are required to be deposited or transferred into the Student Financial Aid account or electronic funds transfersinitiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determinesthat the student withdrew.ConditionFor 1 of the 25 students selected for testing the Title IV funds were not returned within 45 days of the student's withdrawal from theUniversity. The funds were returned 85 days after the student's withdrawal date, which is is 40 days outside the required 45 daywindow. Although the funds were not returned within the required timeframe, the appropriate amount of funds were returned tothe Department of Education.CauseManagement utilizes a weekly ""R2T4 report"", which lists all students that have withdrawn, transferred, or otherwise discontinuedcoursework, to identify students requiring an R2T4 calculation to determine if funds need to be returned. Once the R2T4 calculationand return of funds is complete, the Office of Financial Aid will update the student account information in Banner( system of recordfor student activity), indicating that the requirement has been completed. At this point, the student will no longer appear on theweekly R2T4 report. The student noted above was incorrectly updated as complete for the R2T4 process in Banner. Althoughthe R2T4 calculation had been completed and reviewed, the final return of funds had not yet been processed and reviewed. Therefore,this was considered an error in execution of the control. The student was not listed on the subsequent weeks ""R2T4 report"", whichled to the late return of funds.Questioned CostsThere were no questioned costs related to this finding as the student was eligible to receive Tile IV aid, and the appropriate amountof aid was returned to the Department of Education.EffectIf Management does not complete all requirements for the R2T4 process prior to updating a student account to complete, aidreturned to the Department of Education could be incorrect or not returned at all.RecommendationWe recommend the University continue to enhance the execution of the Title IV return process to ensure all students that withdrawfrom the University have their aid reviewed and returned in a timely manner. The student account information within Banner shouldnot be updated until all procedures, including the final return of funds to the Department of Education, are completed and reviewed."
"Finding 2019-001Grantor: Department of EducationProgram: Student Financial Assistance ClusterCFDA#: 84.268Title: Federal Direct Student Loan ProgramAward Year: 7/1/18-6/30/19Management's ResponseThe Office of Financial Aid acknowledges this finding and will immediately modify the workflow surrounding R2T4 processing.We will review all students the day after R2T4's are processed in order to ensure the funds were successfully returned to COD.Once verifying that all R2T4 requirements, including the successful return of funds to the COD, the staff will then update thestudent account to complete withing Banner."
"Finding 2019-002: EligibilityGrantor: Aids Activity Coordinating Office (AACO)Program: Grants to Provide Outpatient Early Intervention Services with Respect to HIV DiseaseCFDA #: 93.914Title: Ambulatory/Out-Patient Medical Care, Care Services Case ManagementAward Year: 3/1/19-6/30/19Award #: H89HA00013CriteriaPer the AACO/PA Dept. of Health Ryan White Part A/B-Payer of Last Resort Client Certification Form Instructions, ""The HealthResources and Services Administration (HRSA) standards require service providers who receive Ryan White funding to screen clientsand collect supporting documentation to certify their eligibility for Ryan White-funded services based on HIV positive diagnosis,identity, residence, insurance status, and income. The standards further require recertification every 6 months to determine continuedeligibility."" The certification form states under the ""Verification of Insurance"" requirement, ""Having insurance or other third-partycoverage does not deem a client ineligible for Ryan White. However, that coverage should serve as primary in reimbursementof services as Ryan White is to serve as 'Payer of Last Resort' for those services. Verification of eligibility shall remain in theclient's file"".ConditionFor 2 of a sample of 40 patient files selected for testing, the patients were certified as eligible for Ryan White funds, yet eachpatient's insurance did not meet the ""Payer of Last Resort"" requirement.CauseBoth patients were originally certified as eligible based on allowable insurance coverage (i.e. Government programs). However,at their most recent recertification, both patients insurance changed to coverage that did not qualify under the ""Payer of LastResort"" requirement. The patients informed case managers of the change in insurance, but recertification still occurred.Questioned CostsThere are no questioned costs, as the University incurs cost related to the program in excess of budgeted amounts greater thanthe program income noted.EffectThere were no questioned costs related to this finding because City of Philadelphia funds were not specifically reimbursed to theUniversity for the services provided to the inappropriately recertified patients.RecommendationWe recommend the University ensures that changes in insurance are identified and reviewed for all patients during therecertification process. To accomplish this, management should consider implementing a secondary level of review during therecertification process."
Show full finding ▾Hide full finding ▴"Finding 2019-002: EligibilityGrantor: Aids Activity Coordinating Office (AACO)Program: Grants to Provide Outpatient Early Intervention Services with Respect to HIV DiseaseCFDA #: 93.914Title: Ambulatory/Out-Patient Medical Care, Care Services Case ManagementAward Year: 3/1/19-6/30/19Award #: H89HA00013CriteriaPer the AACO/PA Dept. of Health Ryan White Part A/B-Payer of Last Resort Client Certification Form Instructions, ""The HealthResources and Services Administration (HRSA) standards require service providers who receive Ryan White funding to screen clientsand collect supporting documentation to certify their eligibility for Ryan White-funded services based on HIV positive diagnosis,identity, residence, insurance status, and income. The standards further require recertification every 6 months to determine continuedeligibility."" The certification form states under the ""Verification of Insurance"" requirement, ""Having insurance or other third-partycoverage does not deem a client ineligible for Ryan White. However, that coverage should serve as primary in reimbursementof services as Ryan White is to serve as 'Payer of Last Resort' for those services. Verification of eligibility shall remain in theclient's file"".ConditionFor 2 of a sample of 40 patient files selected for testing, the patients were certified as eligible for Ryan White funds, yet eachpatient's insurance did not meet the ""Payer of Last Resort"" requirement.CauseBoth patients were originally certified as eligible based on allowable insurance coverage (i.e. Government programs). However,at their most recent recertification, both patients insurance changed to coverage that did not qualify under the ""Payer of LastResort"" requirement. The patients informed case managers of the change in insurance, but recertification still occurred.Questioned CostsThere are no questioned costs, as the University incurs cost related to the program in excess of budgeted amounts greater thanthe program income noted.EffectThere were no questioned costs related to this finding because City of Philadelphia funds were not specifically reimbursed to theUniversity for the services provided to the inappropriately recertified patients.RecommendationWe recommend the University ensures that changes in insurance are identified and reviewed for all patients during therecertification process. To accomplish this, management should consider implementing a secondary level of review during therecertification process."
"Finding 2019-002Program: Other Sponsored ProjectsCFDA#: 93.914Title: Ambulatory/Out-Patient Medical Care, Care Services Case ManagementAward Year: 3/1/19-6/30/19Award#: H89HA00013Mangement's ResponseManagement agrees with the finding that 2 of the 40 patients that were certified as eligible for Ryan White funds did not meetthe ""Payer of Last Resort"" insurance requirement. The two patients were both previously Ryan White (RW) eligible due to havingMedicaid and/or Special Pharmaceutical Benefit Program (SPBP) coverage. The error was made due to the certifier not checkingtheir current insurance status. In the past year their insurance status had changed from Medicaid and SPBP to private insurance.There was not current proof of income or proof of income by proxy from Medicaid or SPBP.As of October 1, 2019, when a patient of the Partnership Clinic is being certified or recertified for RW services, the medical casemanager doing the certification will check the patient's insurance status in the electronic health record and PROMISe.PROMISe (Provider Reimbursement and Operation Management Information System) is managed by the PennsylvaniaDepartment of Human Services (DHS) which allows access to the portal to check patient eligibility status for Medicaid. If it isMedicaid or SPBP within the past 12 months, that will be used by proxy to satisfy the income requirement for RW certification.If the patient does not have Medicaid or SPBP within the time period and there is no other verification of income, then thepatient will not be certified for RW services and will not receive a card. The Director of Case Management will conduct arandomized survey of 50 patient records every quarter to ascertain that this procedure is being followed correctly."
FAC accepted this audit on December 19, 2018 — management decision was due June 19, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
FAC accepted this audit on March 28, 2018 — management decision was due September 28, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
FAC accepted this audit on March 29, 2017 — management decision was due September 29, 2017.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-002
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-004
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-003
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and filing records.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.
