Wilberforce UniversityHigher Education

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs June 30, 2025 Comment #2025-004 PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT OF FEDERAL PROGRAMS SHOULD BE IMPROVED CONNECTING MINORITY COMMUNITIES PROGRAM HIGHER EDUCATION EMERGENCY RELIEF FUND HIGHER EDUCATIONAL INSTITUTIONAL AID STRENGTHENING MINORITY-SERVING INSTITUTIONS U.S. DEPARTMENT OF EDUCATION ALN# 84.031B and E, 84.382, 84.425T U.S. DEPARTMENT OF COMMERCE ALN#11.028 (Questioned Costs - None) (Repeat 2024-004) Condition: Good internal controls over the receipt of federal funds require the reconciliation of authorized and recorded disbursements of cash drawn from the federal cash management system. This process ensures that federal funds are properly earned by the University and the University has not made a disbursement for which it has not been funded. During our audit, we noted that the University made efforts to reconcile its program activity under the Higher Educational Institutional Aid (Title III), Strengthening Minority-Serving Institutions and the Connecting Minority Communities Program. However, we did not see evidence that the reconciliation of the Title III program activity, Strengthening Minority -Serving Institutions and the Connecting Minority Communities Program is performed regularly as part of the University’s monthly and annual close-out. As a result, we noted the following: • The proper reconciliation of funds disbursed as allowed by the program requires reconciliation of the funds drawn and disbursed for each assistant listing portion (1) a reconciliation of funds disbursed to students directly (student aid portion) and funds disbursed for other allowable expenditures to the general ledger, (2) a reconciliation to the disbursement for general operating purposes and loss revenue to the approved and documented methodology and the general ledger accounts and (3) all funds requested via the G-5 reports should be accurately reconciled to the general ledger and to the various detail reports supporting the disbursements. This procedures also extends to the funds received from the Department of Commerce. The reconciliations should be summarized and reported quarterly and annually as required by the Department of Education and other funding sources. • Financial statement adjustments were needed to properly recognize the cash balance for the Title III program, Strengthening Minority-Serving Institutions and other programs. The reconciliation process, as outlined in the internal control procedures is not performed in a timely manner. Context: Review of cash management procedures related to the Title III-Strengthening Minority-Serving Institutions and the Connecting Minority Communities Program. Criteria: Standards for financial management systems [2 CFR §215.21]. (Continued) Effect: The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not receipting funds that are due to the University for students who have obtained their education. Deficiency in reporting as required by the Department of Commerce. Cause: Weaknesses in procedures over reconciliation of grant activity. Recommendation: We recommend that management implement procedures to ensure that federal program activity is reconciled on a monthly basis for all open award years. This process should be coordinated between all affected departments (i.e., Grants and Contracts, Accounting Department, Sponsored Programs, Student Financial Aid, etc.). The reconciled amounts should properly reflect amounts due to or from the U.S. Department of Education and the U.S. Department of Commerce on the University’s general ledger accounting system. The reconciliations should be reviewed by a responsible official of the University. Monitoring of such reconciliation and the reporting requirements should be evidenced by internal control procedures and proper documentation of authorization. Views of Responsible Officials and Planned Corrective Actions: We concur with the auditor’s finding. The University has engaged a third party to review the reconciliation procedures and to make recommendations on improvements to our current policy. The recommendations will also include any additional documentation that showing proof that the reconciliation has been completed as timely as required. The Vice President of Business & Finance and the Director of Student Financial Aid will review the reconciliations. Monitoring reports will be completed and shared with senior management and relevant department leaders. Implementation date: Immediately and before June 30, 2026. Persons Responsible: Vice President of Business & Finance, controller and Director of Student Financial Aid.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS AND CORRECTIVE ACTION PLAN Federal Award Findings and Questioned Costs June 30, 2025 Comment 2025-005 PROCEDURES SHOULD BE IMPROVED TO ENSURE THAT STUDENTS ARE ELIGIBLE FOR STUDENT FINANCIAL AID STUDENT FINANCIAL AID CLUSTER PROGRAM CFDA # 84.268, 84.063, 84.007, and 84.038 (Questioned Costs-None) Condition: A student is not eligible to receive Title IV, HEA program assistance if the student has not maintained satisfactory academic progress in his or her course of study according to the Institution’s published standards of satisfactory progress that satisfy federal requirements. During our audit, we noticed nine (9) instances in our sample of sixty (60) in which a student did not meet satisfactory academic progress, qualitatively and/or quantitatively. Students were not put on academic status restrictions in a timely manner and in line with the Institution’s policies and procedures. Context: We reviewed the financial aid files of sixty (60) students selected for eligibility testing. Criteria: A student in receipt of Federal funds must maintain satisfactory academic progress in his or her course of study according to the Institution’s published standards of satisfactory progress that satisfy federal requirements [34 CFR 668.32 (f)]. Effect: Compliance with eligibility requirements as established in the Code of Federal Regulations are not met. Ineligible students may be receiving funds, resulting in additional charges to the Institution for unallowable costs. Cause: Transition to remote work environment as a result of the pandemic and inaccurate reviews of student files and miscalculation of financial awards. Recommendation: We recommend that the Institution improve its quality control procedures. Student financial aid award packages should be reviewed before aid is disbursed to ensure eligibility. Management should periodically perform monitoring activities to ensure that federal regulations are followed. All personnel involved in the compilation of the student financial aid packets should be aware of federal regulations which govern the requirements and procedures to be followed when awarding federal aid. Views of Responsible Officials and Planned Corrective Actions: During the FY21 fiscal year the University was sensitive to the significant amount of student concerns related to the abrupt transition from in class room learning to virtual learning environment. Many of them were not prepared for task virtual learning and did not have the proper equipment or experience with virtual learning because many of them had never done remote learning before. The concerns the University considered factors like student and faculty mental health, lack of resources, accessibility to the internet, etc. As a result, the University decided to provide some level of flexibility to the at-risk students and the SAP review process. Corrective action and improvements will be implemented by June 30, 2026 by the Director of Financial Aid.

Condition: Good internal controls over the receipt of federal funds require the reconciliation of authorized and recorded disbursements of cash drawn from the federal cash management system. This process ensures that federal funds are properly earned by the University and the University has not made a disbursement for which it has not been funded. During our audit, we noted that the University made efforts to reconcile its program activity under the COVID-19 Higher Education Emergency Relief Funds (American Rescue Plan - HEERF-III), Higher Educational Institutional Aid (Title III), Strengthening Minority-Serving Institutions and the Connecting Minority Communities Program. However, we did not see evidence that the reconciliation of HEERF funding, Title III program activity, Strengthening Minority -Serving Institutions and the Connecting Minority Communities Program is performed regularly as part of the University’s monthly and annual close-out. As a result, we noted the following: • The proper reconciliation of funds disbursed as allowed by the HEERF III program requires reconciliation of the funds drawn and disbursed for each assistant listing portion (1) a reconciliation of funds disbursed to students directly (student aid portion) and funds disbursed for other allowable expenditures to the general ledger, (2) a reconciliation to the disbursement for general operating purposes and loss revenue to the approved and documented methodology and the general ledger accounts and (3) all funds requested via the G-5 reports should be accurately reconciled to the general ledger and to the various detail reports supporting the disbursements. This procedures also extends to the funds received from the Department of Commerce. The reconciliations should be summarized and reported quarterly and annually as required by the CARES Act (See HEERF Reporting web page) and other funding sources. • Financial statement adjustments were needed to properly recognize the cash balance for the Title III program, Strengthening Minority-Serving Institutions and other programs. The reconciliation process, as outlined in the internal control procedures is not performed in a timely manner. Context: Review of cash management procedures related to the HEERF ,Title III-Strengthening Minority-Serving Institutions and the Connecting Minority Communities Program. Criteria: Standards for financial management systems [2 CFR §215.21] and CARES Act 18004 (ARP). Effect: The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not receipting funds that are due to the University for students who have obtained their education. The failure to not meeting he three components of reporting for HEERF as required by the CARES Act and ARP. Deficiency in reporting as required by the Department of Commerce. Cause: Weaknesses in procedures over reconciliation of grant activity. Recommendation: We recommend that management implement procedures to ensure that federal program activity is reconciled on a monthly basis for all open award years. This process should be coordinated between all affected departments (i.e., Grants and Contracts, Accounting Department, Sponsored Programs, Student Financial Aid, etc.). The reconciled amounts should properly reflect amounts due to or from the U.S. Department of Education and the U.S. Department of Commerce on the University’s general ledger accounting system. The reconciliations should be reviewed by a responsible official of the University. Monitoring of such reconciliation and the reporting requirements should be evidenced by internal control procedures and proper documentation of authorization. Views of Responsible Officials and Planned Corrective Actions: We concur with the auditor’s finding. The University has engaged a third party to review the reconciliation procedures and to make recommendations on improvements to our current policy. The recommendations will also include any additional documentation that showing proof that the reconciliation has been completed as timely as required. The Vice President of Business & Finance and the Director of Student Financial Aid will review the reconciliations. Monitoring reports will be completed and shared with senior management and relevant department leaders. Implementation date: Immediately and before June 30, 2025. Persons Responsible: Vice President of Business & Finance, controller and Director of Student Financial Aid.

Condition: When the Registrar’s Office discovers that a student did not enroll or ceased to be enrolled on at least a half-time basis, the National Student Loan Data System (NSLDS) should be notified of the change in the student’s enrollment status within thirty days of the occurrence, unless the Institution expects to complete its next scheduled filing within sixty days. During our audit, we noted twelve (12) instances in which student status changes were reported more than sixty (60) days after the occurrence. Context: A haphazard selection of fourteen (14) students was made from the list of student withdrawals and graduates during the year. Criteria: Federal regulations require the Institution to notify the NSLDS of a change in student status (i.e., withdrawn, graduated, enrolled less than half-time, etc.). Unless the Institution expects to complete its next filing within sixty days, the Institution must notify the NSLDS within thirty days if it discovers a student with an outstanding federal loan balance has ceased to be enrolled on at least a half-time basis. [34 CFR 685.309] Effect: The lender or guaranty agency is not receiving prompt notification of changes in borrower’s enrollment status. This results in delayed processing of loan repayment periods and leads to poor default management. Late or incorrect updates to the NSLDS may also cause students to receive loans for which they are not eligible, as half-time enrollment is a requirement for Federal Direct Loan (FDL) eligibility. Cause: Necessary withdrawal documentation is not consistently processed and forwarded to appropriate departments in a timely manner to ensure reports are accurately filed as scheduled. Overall, there is an inadequate process of verifying the enrollment status of students. Recommendation: The Institution should implement procedures to ensure compliance with federal regulations. The Registrar’s Office should obtain a complete understanding of the NSLDS reporting requirements. Improving the accuracy and timeliness of student status filings will aid in the transition of students to loan repayment status. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the auditors and has initiated the necessary corrective action plan to mitigate the deficiency from occurring again. The plan is to implement new procedures to ensure the reporting to the NSLDS is done on a timely basis. Implementation date: Immediately and no later than June 30, 2025. Persons Responsible: Vice President of Business & Finance, the Registrars Office and the Director of Student Financial Aid.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs June 30, 2023 Comment #2023-004 PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT OF FEDERAL PROGRAMS SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND HIGHER EDUCATIONAL INSTITUTIONAL AID STRENGTHENING MINORITY-SERVING INSTITUTIONS U.S. DEPARTMENT OF EDUCATION ALN# 84.031B and E, 84.382G, 84.425T (Questioned Costs - None) (Repeat 2022-004) Condition: Good internal controls over the receipt of federal funds require the reconciliation of authorized and recorded disbursements of cash drawn from the federal cash management system. This process ensures that federal funds are properly earned by the University and the University has not made a disbursement for which it has not been funded. During our audit, we noted that the University made efforts to reconcile its program activity under the COVID-19 Higher Education Emergency Relief Funds (American Rescue Plan - HEERF-III), Higher Educational Institutional Aid (Title III), and Strengthening Minority-Serving Institutions. However, we did not see evidence that the reconciliation of HEERF funding and Title III program activity is performed regularly as part of the University’s monthly and annual close-out. As a result, we noted the following: • The proper reconciliation of funds disbursed as allowed by the HEERF III program requires reconciliation of the funds drawn and disbursed for each assistant listing portion (1) a reconciliation of funds disbursed to students directly (student aid portion) and funds disbursed for other allowable expenditures to the general ledger, (2) a reconciliation to the disbursement for general operating purposes and loss revenue to the approved and documented methodology and the general ledger accounts and (3) all funds requested via the G-5 reports should be accurately reconciled to the general ledger and to the various detail reports supporting the disbursements. The reconciliations should be summarized and reported quarterly and annually as required by the CARES Act (See HEERF Reporting web page). • Financial statement adjustments were needed to properly recognize the cash balance for the Title III program, Strengthening Minority-Serving Institutions. The reconciliation process, as outlined in the internal control procedures is not performed in a timely manner. Context: Review of cash management procedures related to the HEERF and Title III-Strengthening Minority-Serving Institutions. Criteria: Standards for financial management systems [2 CFR §215.21] and CARES Act 18004 (ARP). Effect: The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not receipting funds that are due to the University for students who have obtained their education. The failure to not meeting he three components of reporting for HEERF as required by the CARES Act and ARP. 63 WILBERFORCE UNIVERSITY SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs June 30, 2023 Comment #2023-004 PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT OF FEDERAL PROGRAMS SHOULD BE IMPROVED STUDENT FINANCIAL AID CLUSTER PROGRAM HIGHER EDUCATIONAL INSTITUTIONAL AID STRENGTHENING MINORITY-SERVING INSTITUTIONS U.S. DEPARTMENT OF EDUCATION ALN# 84.031B and E, 84.382G, 84.425T (Questioned Costs - None) (Repeat 2022-004) (Continued) Cause: Weaknesses in procedures over reconciliation of grant activity. Recommendation: We recommend that management implement procedures to ensure that federal program activity is reconciled on a monthly basis for all open award years. This process should be coordinated between all affected departments (i.e., Grants and Contracts, Accounting Department, Student Financial Aid, etc.). The reconciled amounts should properly reflect amounts due to or from the U.S. Department of Education on the University’s general ledger accounting system. The reconciliations should be reviewed by a responsible official of the University. Monitoring of such reconciliation and the reporting requirements should be evidenced by internal control procedures and proper documentation of authorization. Views of Responsible Officials and Planned Corrective Actions: We concur with the auditor’s finding. The University has engaged a third party to review the reconciliation procedures and to make recommendations on improvements to our current policy. The recommendations will also include any additional documentation that showing proof that the reconciliation has been completed as timely as required. The Vice President of Business & Finance and the Director of Student Financial Aid will review the reconciliations. Monitoring reports will be completed and shared with senior management and relevant department leaders. Implementation date: Immediately. Persons Responsible: Vice President of Business & Finance, Controller and Director of Student Financial Aid.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS AND CORRECTIVE ACTION PLAN Federal Award Findings and Questioned Costs June 30, 2023 Comment 2023-005 ENROLLMENT REPORTING PROCEDURES SHOULD BE STRENGTHENED STUDENT FINANCIAL AID CLUSTER PROGRAM CFDA # 84.268 (Questioned Costs - None) Condition: When the Registrar’s Office discovers that a student did not enroll or ceased to be enrolled on at least a half-time basis, the National Student Loan Data System (NSLDS) should be notified of the change in the student’s enrollment status within thirty days of the occurrence, unless the Institution expects to complete its next scheduled filing within sixty days. During our audit, we noted three (3) instances in which student status changes were reported more than sixty (60) days after the occurrence. Context: A haphazard selection of ten (10) students was made from the list of student withdrawals and graduates during the year. Criteria: Federal regulations require the Institution to notify the NSLDS of a change in student status (i.e., withdrawn, graduated, enrolled less than half-time, etc.). Unless the Institution expects to complete its next filing within sixty days, the Institution must notify the NSLDS within thirty days if it discovers a student with an outstanding federal loan balance has ceased to be enrolled on at least a half-time basis. [34 CFR 685.309] Effect: The lender or guaranty agency is not receiving prompt notification of changes in borrower’s enrollment status. This results in delayed processing of loan repayment periods and leads to poor default management. Late or incorrect updates to the NSLDS may also cause students to receive loans for which they are not eligible, as half-time enrollment is a requirement for Federal Direct Loan (FDL) eligibility. Cause: Necessary withdrawal documentation is not consistently processed and forwarded to appropriate departments in a timely manner to ensure reports are accurately filed as scheduled. Overall, there is an inadequate process of verifying the enrollment status of students. Recommendation: The Institution should implement procedures to ensure compliance with federal regulations. The Registrar’s Office should obtain a complete understanding of the NSLDS reporting requirements. Improving the accuracy and timeliness of student status filings will aid in the transition of students to loan repayment status. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the auditors and has initiated the necessary corrective action plan to mitigate the deficiency from occurring again. The plan is to implement new procedures to ensure the reporting to the NSLDS is done on a timely basis. Implementation date: Immediately. Persons Responsible: Vice President of Business & Finance, the Registrars Office and the Director of Student Financial Aid.

Comment #2022-004

Comment 2021-004PROCEDURES SHOULD BE IMPROVED TO ENSURE THATSTUDENTS ARE ELIGIBLE FOR STUDENT FINANCIAL AIDSTUDENT FINANCIAL AID CLUSTER PROGRAMCFDA # 84.268, 84.063, 84.007, and 84.038(Questioned Costs-Undetermined)Condition:A student is not eligible to receive Title IV, HEA program assistance if the student has not maintained satisfactoryacademic progress in his or her course of study according to the Institution?s published standards of satisfactory progressthat satisfy federal requirements. During our audit, we noticed seven (7) instances in our sample of sixty (60) in whicha student did not meet satisfactory academic progress, qualitatively and/or quantitatively.Context:We reviewed the financial aid files of sixty (60) students selected for eligibility testing.Criteria:A student in receipt of Federal funds must maintain satisfactory academic progress in his or her course of study accordingto the Institution?s published standards of satisfactory progress that satisfy federal requirements [34 CFR 668.32 (f)].Effect:Compliance with eligibility requirements as established in the Code of Federal Regulations are not met. Ineligiblestudents may be receiving funds, resulting in additional charges to the Institution for unallowable costs.Cause:Transition to remote work environment as a result of the pandemic and inaccurate reviews of student files andmiscalculation of financial awards.Recommendation:We recommend that the Institution improve its quality control procedures. Student financial aid award packages shouldbe reviewed before aid is disbursed to ensure eligibility. Management should periodically perform monitoring activitiesto ensure that federal regulations are followed. All personnel involved in the compilation of the student financial aidpackets should be aware of federal regulations which govern the requirements and procedures to be followed whenawarding federal aid.Views of Responsible Officials and Planned Corrective Actions:During the FY21 fiscal year the University was sensitive to the significant amount of student concerns related to theabrupt transition from in class room learning to virtual learning environment. Many of them were not prepared for taskvirtual learning and did not have the proper equipment or experience with virtual learning because many of them hadnever done remote learning before. The concerns the University considered factors like student and faculty mentalhealth, lack of resources, accessibility to the internet, etc. As a result, the University decided to provide some level offlexibility to the at-risk students and the SAP review process. Therefore, a temporary wavier of the SAP policy wasgiven under the COVID-19 pandemic on a case by case basis during the 2021 fiscal year.

Comment 2021-005PROCEDURES USED TO IDENTIFY STUDENTS FOR THE RETURN OF TITLE IV FUNDSSHOULD BE IMPROVEDSTUDENT FINANCIAL AID CLUSTER PROGRAMCFDA # 84.268(Questioned Costs-Undetermined)Condition:When a recipient of Title IV grant or loan assistance withdraws from an institution of higher learning during a paymentperiod or period of enrollment in which the recipient began attendance, the institution must determine the amount of TitleIV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by thestudent is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?sdetermination that the student withdrew, the difference must be returned to the Title IV programs as outlined in theregulations.During our audit we noted that the University?s did not perform the R2T4 calculations in a timely manner as requiredby the Department of Education regulations.Context:Review of internal controls and related procedures in place for identifying students ceasing to attend or enroll and theprocedures in place to identify when a student withdraws or fail to properly enroll. Policies in place to determine thetimeliness of calculating the required return of federal funds as prescribed by the Department of Education.Criteria:Controls should be in place to ensure that when a student ceases to attend the University the proper procedures arefollowed.The financial aid personnel and the accounting department and the management accounting systems of each non-Federalentity must provide for, effective controls over, and accountability for all students the withdraws from the University[2 CFR ?668.22].Effect:Management may not be able to obtain complete and accurate information to determine when a student withdraws fromthe University and therefore, not properly calculate the R2T4 funds.Cause:Transition to remote work environment as a result of the pandemic and weaknesses in processes related to proceduresdetermining official withdrawals, un-official withdrawals and students failing to return or those62WILBERFORCE UNIVERSITYSCHEDULE OF FINDINGS AND QUESTIONED COSTS AND CORRECTIVE ACTION PLANFederal Award Findings and Questioned CostsJune 30, 2021Comment 2021-005PROCEDURES USED TO IDENTIFY STUDENTS FOR THE RETURN OF TITLE IV FUNDS SHOULDBE IMPROVEDSTUDENT FINANCIAL AID CLUSTER PROGRAMCFDA # 84.268(Questioned Costs-Undetermined)Comment 2021-005 (Continued)Recommendation:The policies and procedures in place to identify students withdrawing from the University should be reviewed andimproved to ensure that when a student ceases to enroll or withdraws from the institution (officially or un-officially) theproper procedures are followed, as outlined in the federal regulations. Timely R2T4 calculations should be performedand appropriate grant or loan funds should be timely remitted back to the Department of Education.Views of Responsible Officials and Planned Corrective Actions:During fiscal year ending 2021, the University modified procedures related to certain R2T4 compliance requirementsunder Section 3508 of the CARES Act.Section 3508 of the CARES Act directs the Secretary to waive the statutory requirement for institutions to return TitleIV funds as the result of student withdrawals related to a qualifying emergency. For any student who begins attendancein a payment period or period of enrollment that includes March 13, 2020, or begins between March 13 and the later ofDecember 31 or the last date that the national emergency is in effect, and subsequently withdraws from the period as aresult of COVID-19 relate circumstances, an institution is not required to return Title IV funds. Calculations have andwill be performed for all unofficial and official withdrawals.

Comment #2021-006PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENTOF FEDERAL PROGRAM SHOULD BE IMPROVEDSTUDENT FINANCIAL AID CLUSTER PROGRAMHIGHER EDUCATION EMERGENCY RELIEF FUNDHIGHER EDUCATIONAL INSTITUTIONAL AIDSTRENGTHENING MINORITY-SERVICING INSTITUTIONSU.S. DEPARTMENT OF EDUCATIONCFDA # 84.007, 84.033, 84.038, 84.063, 84.268, 84.031, 84.382, 84.425 (E,F,J)(Questioned Costs - None)(Repeat - 2020-005)Condition:Good internal controls over the receipt of federal funds requires the reconciliation of authorized and recordeddisbursements whine cash drawn down in the federal cash management system. This process ensures that federal fundsare properly earned by the University and the University has not made a disbursement for which it has not been funded.During our audit, we noted that the University made efforts to reconcile its program activity under the Student FinancialAid Cluster (Title IV),COVID-19 Higher Education Emergency Relief Funds, Higher Educational Institutional Aid(Title III), and Strengthening Minority-Servicing Institutions. However, we did not see evidence that the reconciliationof Title IV and Title III program activity is performed regularly as part of the University?s monthly close-out. As aresult, we noted the following:? The proper reconciliation of certain Title IV grants (i.e., Federal Pell, FSEOG, FWS and Direct Loan) requiresa ?three-way? reconciliation of the financial aid awards, general ledger postings (disbursements), anddrawdowns per the G-5. We did not see evidence that the amounts disbursed per the student accounts wereagreed to the list of students authorized through the Common Origination and Disbursements. The Universitydoes track the students posting through the internal system with Banner software; however, the system is notreconciled in a timely manner.? Financial statement adjustments were needed to properly recognize the cash balance for the Title III program,and Strengthening Minority-Servicing Institutions. The reconciliation process, as outlined in the internal controlprocedures are not performed in a timely manner nor reviewed by a responsible official with the skills,knowledge and experience.Context:Review of cash management procedures related to the Title III, Title IV programs, HEERF, and Strengthening Minority-Servicing Institutions.Criteria:Standards for financial management systems [2 CFR ?215.21]Effect:The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or notreceipting funds that are due to the College for students who have obtained their education.Cause:Weaknesses in procedures over reconciliation of grant activity.Recommendation:We recommend that management implement procedures to ensure that federal program activity is reconciled on amonthly basis for all open award years. This process should be coordinated between all affected departments (i.e.,Grants and Contracts, Accounting Department, Student Financial Aid, etc.). The reconciled amounts should properlyreflect amounts due to or from the U.S. Department of Education on the University?s general ledger accounting system.The reconciliations should be reviewed by a responsible official of the University.Views of Responsible Officials and Planned Corrective Actions:We concur with the auditor?s finding. The University has engaged a third party to review our reconciliation proceduresand to make recommendations on improvements to our current policy. The recommendations will also include anyadditional documentation that shows proof that the reconciliation has been completed in a timely manner as required.The Vice President of Business & Finance and the Director of Student Financial Aid will review the reconciliations.Implementation date: December, 2022.Persons Responsible: Vice President of Business & Finance, Business Office and Director of Student Financial Aid.

Comment #2020-004ENROLLMENT REPORTING PROCEDURES SHOULD BE STRENGTHENEDSTUDENT FINANCIAL AID CLUSTER PROGRAMU.S. DEPARTMENT OF EDUCATIONCFDA # 84.268(Questioned Costs - None)(Repeat - 2019-004)Condition:When the Registrar?s Office discovers that a student did not enroll or ceased to be enrolled on at least a half-time basis,the National Student Loan Data System (NSLDS) should be notified of the change in the student?s enrollment statuswithin thirty days of the occurrence, unless the Institution expects to complete its next scheduled filing within sixty days.During our audit, we noted ten (10) instances in which student status changes were reported more than sixty days afterthe occurrence.Context:We obtained a list of student withdrawals and graduates during the year. A haphazard selection was made of fifteenstudents for testing.Criteria:Institutions must periodically complete and return within thirty days of receipt, roster files (formerly student statusconfirmation reports) submitted by the NSLDS. Unless the Institution expects to complete its next filing within sixtydays, the Institution must notify the NSLDS within thirty days if it discovers a student with an outstanding federal loanbalance has ceased to be enrolled on at least a half-time basis. [34 CFR 682.610?]Effect:The lender or guaranty agency is not receiving prompt notification of changes in borrower?s enrollment status. Thisresults in delayed processing of loan repayment periods and leads to poor default management. Late or incorrect updatesto the NSLDS may also cause students to receive loans for which they are not eligible, as half-time enrollment is arequirement for Federal Direct Loan (FDL) eligibility.Cause:Technical difficulties in submitting reports between the Institution and the NSLDS were noted during the year. Inaddition, necessary withdrawal documentation is not consistently processed and forwarded to appropriate departmentsin a timely manner to ensure reports are accurately filed as scheduled. There are also inconsistencies in the manner inwhich roster files are updated for reporting purposes.Recommendation:We recommend that all personnel involved in the enrollment reporting process be reminded of the need to accuratelyreport student status changes to the NSLDS in a timely manner. Any technical problems encountered in updating andsubmitting reports should be investigated to ensure compliance with applicable federal regulations.Views of Responsible Officials and Planned Corrective Actions:We concur with the auditor?s finding. We are hiring an assistant registrar. The job description for that position has afocus on monitoring and reporting student statuses timely. We are also focusing on cross training the Registrar?s staffin the Enrollment reporting process to ensure that the enrollment reporting is done timely.Implementation date: December, 2021.Persons responsible: Registrar, Vice President of Academic Affairs and Director of Student Financial Aid.

Comment #2020-005PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENTOF FEDERAL PROGRAM SHOULD BE IMPROVEDSTUDENT FINANCIAL AID CLUSTER PROGRAMHIGHER EDUCATIONAL INSTITUTIONAL AIDSTRENGTHENING MINORITY-SERVICING INSTITUTIONSU.S. DEPARTMENT OF EDUCATIONCFDA # 84.007, 84.033, 84.038, 84.063, 84.268, 84.031, 84.382, 84.425 (E,F,J)(Questioned Costs - None)(Repeat - 2019-005)Condition:Good internal controls over the receipt of federal funds requires the reconciliation of authorized and recordeddisbursements whine cash drawn down in the federal cash management system. This process ensures that federal fundsare properly earned by the University and the University has not made a disbursement for which it has not been funded.During our audit, we noted that the University made efforts to reconcile its program activity under the Student FinancialAid Cluster (Title IV),COVID-19 Higher Education Emergency Relief Funds, Higher Educational Institutional Aid(Title III), and Strengthening Minority-Servicing Institutions. However, we did not see evidence that the reconciliationof Title IV and Title III program activity is performed regularly as part of the University?s monthly close-out. As aresult, we noted the following:? The proper reconciliation of certain Title IV grants (i.e., Federal Pell, FSEOG, FWS and Direct Loan) requiresa ?three-way? reconciliation of the financial aid awards, general ledger postings (disbursements), anddrawdowns per the G-5. We did not see evidence that the amounts disbursed per the student accounts wereagreed to the list of students authorized through the Common Origination and Disbursements. The Universitydoes track the students posting through the internal system with Banner software; however, the system is notreconciled in a timely manner.? Financial statement adjustments were needed to properly recognize the cash balance for the Title III program,and Strengthening Minority-Servicing Institutions. The reconciliation process, as outlined in the internal controlprocedures are not performed in a timely manner nor reviewed by a responsible official with the skills,knowledge and experience.Context:Review of cash management procedures related to the Title III, Title IV programs, HEERF, and Strengthening Minority-Servicing Institutions.Criteria:Standards for financial management systems [2 CFR ?215.21]Effect:The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or notreceipting funds that are due to the College for students who have obtained their education.Cause:Weaknesses in procedures over reconciliation of grant activity.Recommendation:We recommend that management implement procedures to ensure that federal program activity is reconciled on amonthly basis for all open award years. This process should be coordinated between all affected departments (i.e.,Grants and Contracts, Accounting Department, Student Financial Aid, etc.). The reconciled amounts should properlyreflect amounts due to or from the U.S. Department of Education on the University?s general ledger accounting system.The reconciliations should be reviewed by a responsible official of the University.Views of Responsible Officials and Planned Corrective Actions:We concur with the auditor?s finding. The University has engaged a third party to review our reconciliation proceduresand to make recommendations on improvements to our current policy. The recommendations will also include anyadditional documentation that shows proof that the reconciliation has been completed in a timely manner as required.The Vice President of Business & Finance and the Director of Student Financial Aid will review the reconciliations.Implementation date: December, 2021.Persons Responsible: Vice President of Business & Finance, Business Office and Director of Student Financial Aid.59

Comment #2019-004 ENROLLMENT REPORTING PROCEDURES SHOULD BE STRENGTHENED STUDENT FINANCIAL AID CLUSTER PROGRAM U.S. DEPARTMENT OF EDUCATION CFDA # 84.268 (Questioned Costs - None) (Repeat - 2018-004) Condition: When the Registrar?s Office discovers that a student did not enroll or ceased to be enrolled on at least a half-time basis, the National Student Loan Data System (NSLDS) should be notified of the change in the student?s enrollment status within thirty days of the occurrence, unless the Institution expects to complete its next scheduled filing within sixty days. During our audit, we noted ten (10) instances in which student status changes were reported more than sixty days after the occurrence. Context: We obtained a list of student withdrawals and graduates during the year. A haphazard selection was made of fifteen students for testing. Criteria: Institutions must periodically complete and return within thirty days of receipt, roster files (formerly student status confirmation reports) submitted by the NSLDS. Unless the Institution expects to complete its next filing within sixty days, the Institution must notify the NSLDS within thirty days if it discovers a student with an outstanding federal loan balance has ceased to be enrolled on at least a half-time basis. [34 CFR 682.610(c)] Effect: The lender or guaranty agency is not receiving prompt notification of changes in borrower?s enrollment status. This results in delayed processing of loan repayment periods and leads to poor default management. Late or incorrect updates to the NSLDS may also cause students to receive loans for which they are not eligible, as half-time enrollment is a requirement for Federal Direct Loan (FDL) eligibility. Cause: Technical difficulties in submitting reports between the Institution and the NSLDS were noted during the year. In addition, necessary withdrawal documentation is not consistently processed and forwarded to appropriate departments in a timely manner to ensure reports are accurately filed as scheduled. There are also inconsistencies in the manner in which roster files are updated for reporting purposes. Recommendation: We recommend that all personnel involved in the enrollment reporting process be reminded of the need to accurately report student status changes to the NSLDS in a timely manner. Any technical problems encountered in updating and submitting reports should be investigated to ensure compliance with applicable federal regulations.

Comment #2019-005 PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT OF FEDERAL PROGRAM SHOULD BE IMPROVED STUDENT FINANCIAL AID CLUSTER PROGRAM HIGHER EDUCATIONAL INSTITUTIONAL AID STRENGTHENING MINORITY-SERVICING INSTITUTIONS U.S. DEPARTMENT OF EDUCATION CFDA # 84.007, 84.033, 84.038, 84.063, 84.268, 84.031, 84.382 (Questioned Costs - None) (Repeat - 2018-005 Condition: Good internal controls over the receipt of federal funds requires the reconciliation of authorized and recorded disbursements whine cash drawn down in the federal cash management system. This process ensures that federal funds are properly earned by the University and the University has not made a disbursement for which it has not been funded. During our audit, we noted that the University made efforts to reconcile its program activity under the Student Financial Aid Cluster (Title IV), Higher Educational Institutional Aid (Title III), and Strengthening Minority-Servicing Institutions. However, we did not see evidence that the reconciliation of Title IV and Title III program activity is performed regularly as part of the University?s monthly close-out. As a result, we noted the following: ? The proper reconciliation of certain Title IV grants (i.e., Federal Pell and Direct Loan) requires a ?three-way? reconciliation of the financial aid awards, general ledger postings (disbursements), and drawdowns per the G-5. We did not see evidence that the amounts disbursed per the student accounts were agreed to the list of students authorized through the Common Origination and Disbursements. The University does track the students posting through the internal system with Banner software; however, the system is not reconciled in a timely manner. ? Financial statement adjustments were needed to properly recognize the cash balance for the Title III program, and Strengthening Minority-Servicing Institutions. The reconciliation process, as outlined in the internal control procedures are not performed in a timely manner nor reviewed by a responsible official with the skills, knowledge and experience. Context: Review of cash management procedures related to the Title III, Title IV programs, and Strengthening Minority-Servicing Institutions. Criteria: Standards for financial management systems [2 CFR ?215.21] Effect: The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not receipting funds that are due to the College for students who have obtained their education. Cause: Weaknesses in procedures over reconciliation of grant activity. Recommendation: We recommend that management implement procedures to ensure that federal program activity is reconciled on a monthly basis for all open award years. This process should be coordinated between all affected departments (i.e., Grants and Contracts, Accounting Department, Student Financial Aid, etc.). The reconciled amounts should properly reflect amounts due to or from the U.S. Department of Education on the University?s general ledger accounting system. The reconciliations should be reviewed by a responsible official of the University.

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