Sarah Lawrence CollegeHigher Education

Finding 2022-001 Special Tests and Provisions - Enrollment Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education ? Education Stabilization Fund COVID-19: Higher Education Emergency Relief Fund ? Student Aid Portion (ALN 84.425E) Federal Award Number: P425E201024 COVID-19: Higher Education Emergency Relief Fund ? Institutional Portion (ALN 84.425F) Federal Award Number: P425F200606 Federal Award Year: 2021-2022 Criteria: Institutions that received and expended funding under the Higher Education Emergency Relief Fund (?HEERF?) Grants Program of the Education Stabilization Fund were required to post certain reports and information to their website relating to the institutions? expenditure of such funds (referred to as Quarterly Public Reporting). For the HEERF Student Aid Portion, required information to be posted to institutions? website includes, but is not limited to: ? The total amount of Emergency Financial Aid Grants distributed to students under the Coronavirus Aid, Relief, and Economic Security Act (?CARES?) (a)(1) subprogram and the Coronavirus Response and Relief Supplemental Appropriations Act (?CRRSAA?) and American Rescue Plan (?ARP?) (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). ? The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. ? The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. ? The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. For the HEERF Student Aid Portion, institutions must publicly post their Quarterly Report as soon as possible, but no later than 30 days after the publication of the U.S. Department of Education?s (?ED?) Notice of Public Posting Requirement of Grant Information for HEERF Grantees (i.e. May 13, 2021) or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). For the HEERF Institutional Portion, institutions must post completed Quarterly Report forms on their website. A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10). Context and Condition: The College did not prepare and post to its website the required Quarterly Public Reporting form and information relating to its HEERF II and III Student Aid and Institutional Portions. Cause: During 2021, the College was unaware of the Quarterly Reporting requirements related to the HEERF funds. Due to the timing of the completion of the FY2021 audit, the College did not have time to correct the quarterly reporting, therefore impacting FY2022 as well. Although the College was aware of the requirements in FY2022, due to turnover in staff, the College is working with the Office of Postsecondary Education on retroactively meeting the reporting requirement. Effect: The required information and form relating to the HEERF II and III Quarterly Public Reporting requirements were not prepared and posted to the College?s website. Questioned Costs: None identified. Identified as a Repeat Finding: Yes. Recommendation: The College should implement procedures to ensure that reporting requirements relating to HEERF awards are identified on a timely basis and that the College monitors its compliance with such requirements. Views of Responsible Officials: See Corrective Action Plan.

Finding 2021-001 Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education ? Education Stabilization Fund COVID-19: Higher Education Emergency Relief Fund ? Student Aid Portion (ALN 84.425E) Federal Award Number: P425E201024 COVID-19: Higher Education Emergency Relief Fund ? Institutional Portion (ALN 84.425F) Federal Award Number: P425F200606 Federal Award Year: 2020-2021 Criteria: Institutions that received and expended funding under the Higher Education Emergency Relief Fund (?HEERF?) Grants Program of the Education Stabilization Fund were required to post certain reports and information to their website relating to the institutions? expenditure of such funds (referred to as Quarterly Public Reporting). For the HEERF Student Aid Portion, required information to be posted to institutions? website includes, but is not limited to: ? The total amount of Emergency Financial Aid Grants distributed to students under the Coronavirus Aid, Relief, and Economic Security Act (?CARES?) (a)(1) subprogram and the Coronavirus Response and Relief Supplemental Appropriations Act (?CRRSAA?) and American Rescue Plan (?ARP?) (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). ? The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. ? The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. ? The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. For the HEERF Student Aid Portion, institutions must publicly post their Quarterly Report as soon as possible, but no later than 30 days after the publication of the U.S. Department of Education?s (?ED?) Notice of Public Posting Requirement of Grant Information for HEERF Grantees (i.e. May 13, 2021) or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). For the HEERF Institutional Portion, institutions must post completed Quarterly Report forms on their website. A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which is due July 10, 2021. Context and Condition: The College did not prepare and post to its website the required Quarterly Public Reporting form and information relating to its HEERF II Student Aid and Institutional Portions. Cause: The College was unaware of the Quarterly Public Reporting requirements relating to HEERF II funds. Effect: The required information and form relating to the HEERF II Quarterly Public Reporting requirements were not prepared and posted to the College?s website. Questioned Costs: None identified. Identified as a Repeat Finding: No. Recommendation: The College should implement procedures to ensure that reporting requirements relating to HEERF awards are identified on a timely basis and that the College monitors its compliance with such requirements. Views of Responsible Officials:

Finding 2021-002 Special Tests and Provisions - Enrollment Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Student Loans (ALN 84.268) Federal Award Number: P268K211880 Federal Pell Grant Program (ALN 84.063) Federal Award Number: P063P201880 Federal Award Year: 2020-2021 Criteria: Under the Federal Pell Grant Program and U.S. Department of Education (?ED?) loan programs, institutions are required to report student enrollment information via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS maintains as the most recently certified enrollment information. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Required campus-level data includes: ? Office of Postsecondary Education Identifier (?OPEID?); ? Enrollment status; and ? Enrollment effective date. Required program-level data includes, but is not limited to: ? Program enrollment status; ? Program enrollment effective date; ? Program begin date; ? Published program length and measurement; and ? Classification of Instructional Program (?CIP?) code. Context and Condition: From a selection of eighteen (18) students tested, we identified the following instances of noncompliance: 1) For ten (10) students, the program begin dates that were reported to the NSLDS did not reflect the first day of the earliest semester in which such students began attending the respective programs being reported. 2) For seventeen (17) students, the enrollment effective dates of their Graduated status were reported to the NSLDS differently between the students? campus-level and program-level records. Such enrollment effective dates that were reported in the students? campus-level records represented the last day of the last academic semester attended by the students while such enrollment effective dates that were reported in the students? program-level records represented the date that academic degrees were conferred to such students, which were at a date subsequent to the last day of the last academic semester attended by the students. Cause: Due to the manner in which the College?s enrollment and financial aid systems have been programmed to report such information, the identified students? program begin dates and enrollment effective dates were inaccurately reported to the NSLDS. Effect: The program begin dates for ten (10) students and the Graduated status enrollment effective dates for seventeen (17) students were not properly reported to the NSLDS. Questioned Costs: None identified. Identified as a Repeat Finding: No. Recommendation: The College should review and update its enrollment and financial aid systems to ensure that students? program begin dates and status change enrollment effective dates are reported to the NSLDS accurately and in accordance with the NSLDS Enrollment Guide. Views of Responsible Officials:

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