Shawnee State UniversityHigher Education

Assistance Listing Number, Federal Agency, and Program Name - ALNs 84.063 and 84.268; Department of Education; Federal Pell Grant Program and Federal Direct Loan Program Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022 001 Criteria - Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education (ED) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew (34 CFR 668.173(b)). Condition - The University did not return Title IV funds to the Department of Education within the required time frame for certain students who required a return of funds, and it did not initially identify all students who required a return of Title IV funds. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 withdrawn students tested for proper return of Title IV funds, the funds for 3 students requiring a return were not returned to ED by the University within the required time frame. The 3 errors identified were for the fall 2022 and spring 2023 term. Cause and Effect - The University had a change in system and it changed the process for exporting withdrawal reports. This led to returns of Title IV funds to ED being completed outside the required time frame, and/or students who required a return of Title IV funds were missed. Recommendation - We recommend that the University institute a process to ensure that all returns of Title IV aid are calculated and returned within the required time frame. Views of Responsible Officials and Corrective Action Plan - Shawnee State University will perform a comprehensive review of financial aid procedures (including review of financial aid processing, personnel responsibilities, and system modifications) and make revisions to workflows to prevent future occurrence of this finding. A review of activity prior to implementation of revised procedures will be conducted, and any exceptions will be documented and corrected.

Assistance Listing Number, Federal Agency, and Program Name - ALNs 84.063 and 84.268; Department of Education; Federal Pell Grant Program and Federal Direct Loan Program Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022 002 Criteria - Federal Pell Grant Program: An institution shall submit, in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct (34 CFR Section 690.83(b)(2)). Federal Direct Student Loans: Changes in student status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change (34 CFR Section 685.309(b)). Condition - Shawnee State University did not report student status changes timely and accurately for certain students who withdrew during the year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested for student change status, 5 student status changes were not submitted within the required time frame and were not properly reported as withdrawn. Cause and Effect - The University did not have a process in place in order to ensure timely and proper reporting for all student status changes. As a result, there were instances of reporting outside of the required time frame and instances where reporting was incorrect. Recommendation - We recommend that the University put a control process in place in order to ensure all student status changes are reported timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Shawnee State University will perform a comprehensive review of financial aid procedures (including review of financial aid processing, personnel responsibilities, and system modifications) and make revisions to workflows to prevent future occurrence of this finding. A review of activity prior to implementation of revised procedures will be conducted, and any exceptions will be documented and corrected.

Assistance Listing Number, Federal Agency, and Program Name - ALNs 84.268; Department of Education; Federal Direct Loan Program Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - If a student account is credited with Federal Direct Loans (FDL), the institution must notify the student or parent of date and amount as well as the right to cancel all or portion of loan, and the procedure and time by which the student must notify the institution no earlier than 30 days before and no later than 30 days after crediting student’s account if using an affirmative confirmation process (34 CFR Section 68.165). Condition - The University did not timely notify the student or parent within 30 days of crediting the student's account with Federal Direct Loans. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 21 students tested for FDL notification, notifications for 16 students were not timely communicated within the required time frame. Cause and Effect - The University did not have a process in place to ensure notifications were sent out in the required time frame. Recommendation - We recommend that the University institute a process to ensure that all notifications are sent within the required time frame. Views of Responsible Officials and Planned Corrective Actions - When posting direct loans to the student's account, we will add a touchpoint to the student's record. This automatically sends an email to the student. We will mail a notification to the parent in the case of a Parent Plus loan.

2022 001 Assistance Listing Number, Federal Agency, and Program Name - ALN Nos. 84.063 and 84.268; Department of Education; Federal Pell Grant Program and Federal Direct Loan Program Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-003 Criteria - Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education (ED) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew (34 CFR 668.173(b)). Condition - The University did not return Title IV funds to the Department of Education within the required time frame for certain students who required a return of funds, and it did not initially identify all students who required a return of Title IV funds. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 withdrawn students tested for proper return of Title IV funds, the funds for 7 students requiring a return were not returned to ED by the University within the required time frame. The 7 errors identified were for the summer and fall 2021 terms. Additionally, it was noted that 3 students in the summer and fall 2021 terms who required a return of Title IV had not been identified by the University, consisting of a total return of $5,581. The University ran an updated report that covered missing students and properly calculated and provided returns of Title IV aid for these students after identification as part of audit procedures; as such, there are no questioned costs. Cause and Effect - The University had a change in personnel in the financial aid department and did not have a process in place to ensure calculations performed were processed and returned to ED within the required time frame. This led to returns of Title IV funds to ED being completed outside the required time frame, and/or students who required a return of Title IV funds were missed. Recommendation - We recommend that the University institute a process to ensure that all returns of Title IV aid are calculated and returned within the required time frame. Views of Responsible Officials and Corrective Action Plan - Upon notification of Finding No. 2021-003, a new R2T4 process was created for the spring 2022 academic term. This process consists of creating a new report to identify students who withdrew from all courses during each academic term. Once the R2T4 calculation is completed, the aid adjustment is made in the financial aid system and posted to the student's account the same day. The aid amounts are manually adjusted in COD. All audit errors related to Finding No. 2022-001 are from the summer 2021 and fall 2021 academic terms. There were no errors in the audit sample for spring 2022. The new procedure continues to be in place.

2022 002 Assistance Listing Number, Federal Agency, and Program Name - ALN Nos. 84.063 and 84.268; Department of Education; Federal Pell Grant Program and Federal Direct Loan Program Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Federal Pell Grant Program: An institution shall submit, in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct (34 CFR Section 690.83(b)(2)). Federal Direct Student Loans: Changes in student status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change (34 CFR Section 685.309(b)). Condition - Shawnee State University did not report student status changes timely and accurately for certain students who graduated or withdrew during the year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested for student change status, 15 student status changes were not submitted within the required time frame, and 4 students were not properly reported as graduated or withdrawn. Cause and Effect - The University did not have a process in place in order to ensure timely and proper reporting for all student status changes. As a result, there were instances of reporting outside of the required time frame and instances where reporting was incorrect. Recommendation - We recommend that the University put a control process in place in order to ensure all student status changes are reported timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Prior to an enrollment report being uploaded to the National Student Clearinghouse, the Recalculate Academic Record process in our student information system, currently J1, will be run to identify any student registration records that may be stuck in a current status due to a mixed "Repeat" status. Those records will be corrected as needed. The office underwent major staffing changes, which caused a delay in submitting reports in a timelier manner. The staffing issues have been resolved, and reports are uploaded on the scheduled submission date.

2022 003 Assistance Listing Number, Federal Agency, and Program Name - ALN No. 84.425F; Department of Education; Higher Education Emergency Relief Fund Institutional Portion Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Per the grant award and frequently asked questions provided by the Department of Education, the Higher Education Emergency Relief Fund Institutional Portion grant was required to be used for activities to "prevent, prepare for, and respond to the coronavirus." Further, the Higher Education Emergency Relief Fund III frequently asked questions guidance released by the Department of Education provides that institutions may use grant funds "to pay for certain payroll costs, including employee benefits, if (1) such costs are newly associated with coronavirus and (2) the costs were incurred on or after March 13, 2020, the date of the declaration of the national emergency due to the coronavirus." Condition - The University charged unallowable payroll expenditures to the grant, as they were for payroll costs and related employee benefits that were not for costs newly associated with the coronavirus or to prevent, prepare for, or respond to the coronavirus. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 50 expenditures selected for testing of activities allowed or unallowed, 1 expenditure for faculty payroll was noted that was not allowable, as it was not newly associated with the coronavirus. The expenditure was allowable through the summer 2021 term, as the faculty role had been hired to provide for decreased class sizes due to the coronavirus. However, beginning with the fall 2021 term, decreased class sizes were no longer required by the University, but the University continued to charge the faculty member's salary to the grant. Total unallowed costs related to this issue were $40,232. However, after including allowable lost revenue of approximately $4.2 million, total expenditures incurred by the University exceeded the total grant award by approximately $2.7 million. As such, these unallowed costs are not questioned costs, as allowable lost revenue would be able to be claimed by the University to replace the unallowed costs. Cause and Effect - The University did not have a fully operating process in place to ensure that periodic costs charged to the grant continued to be for activities to prevent, prepare for, and respond to the coronavirus. Recommendation - We recommend that the University put a control process in place to ensure that all ongoing payroll costs charged to the grant are for costs associated with the coronavirus. Views of Responsible Officials and Planned Corrective Actions - Shawnee State University has discontinued charging salaries to the HEERF award. Any potential new salaries or payments for services will be reviewed and evaluated by the program director to certify that the expenses are costs newly associated with the coronavirus or to prevent, prepare for, or respond to the coronavirus

Assistance Listing Number, Federal Agency, and Program Name - ALN Nos. 84.425E and 84.425F; Department of Education; Higher Education Emergency Relief Fund Student Portion and Higher Education Emergency Relief Fund Institutional Portion Federal Award Identification Number and Year N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - CARES Act 18004(e) and the CRRSAA 314(e) require an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. ARP Act 2003 specifies that the same terms and conditions of CRRSAA 314 apply to HEERF III funds. While the Acts do not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, pursuant to these requirements, the Department of Education required quarterly public reporting of student portion and institutional portion awards. Condition - The University did not complete all required quarterly public reporting for the Higher Education Emergency Relief Fund student portion or institutional portion awards as required during the year ended June 30, 2021. Questioned Costs - None Identification of How Questioned Costs Were Computed N/A Context - The University did not complete the required quarterly public reporting for the Higher Education Emergency Relief Fund student portion or institutional portion awards for the quarters ending December 2020, March 2021, or June 2021. Cause and Effect - The University did not track all due dates and reporting requirements in order to ensure that the quarterly public reporting was completed at the frequency required. Recommendation - We recommend the University put in place a process in order to ensure that all report due dates are tracked to ensure that all required reports are submitted. Views of Responsible Officials and Corrective Action Plan - Due to the addition of multiple funding sources and amounts of COVID 19 related awards as well as revisions to the guidelines for allowable uses of the funds (such as allowance for lost revenue capture) during fiscal year 2021, the allocation of expenditures to the appropriate awards was being constantly evaluated. Due to the significant impact some of these changes would have on our reports, the University deferred submission of the final versions of the required reports instead of filing initial reports and several subsequent revisions. Quarterly reports for fiscal year 2021 will be completed and posted to the appropriate websites. Quarterly reports for fiscal year 2022 will be prepared and posted by the required deadline. The 2022 first quarter student and institutional expenditure reports have already been posted as required.

Assistance Listing Number, Federal Agency, and Program Name - ALN No. 84.425F; Department of Education; Higher Education Emergency Relief Fund Institutional Portion Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; be adequately documented; and not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (2 CFR 200.403(a),(f),(g)) Condition - The University charged unallowable expenditures and lost revenue to the grant as they were for activities previously charged to the grant or not calculated properly. Questioned Cost - $141,477 Identification of How Questioned Costs Were Computed - Questioned costs were determined based on one amount that was previously charged during the year ended June 30, 2020 and had already been drawn down on the grant. Other errors identified were corrected by management. Context - The University charged a payment to a third party housing contractor related Spring 2020 housing of $141,477 in addition to charging housing refunds paid to students for related housing for Spring 2020 during the year ended June 30, 2020. As such, the same activity was reimbursed by the grant twice. In addition, the University's lost revenue calculations were initially overstated by $360,826 due to calculation errors and general ledger entries recorded after the calculation was completed. The University corrected the errors in the calculation, and as such, there is not a questioned cost related to the lost revenue error. Cause and Effect - The University did not consider all costs charged to the grant that could be related to previously charged costs for the same activity and, therefore, not allowable under uniform guidance cost principles. Additionally, the University did not have an adequate review process in place over the lost revenue calculation. As a result, the University overstated expenditures and lost revenue charged to the grant. Recommendation - We recommend the University implement a detailed review process over lost revenue calculations. We also recommend the University consider whether costs charged to the grant may be related to the same activity and, therefore, not allowable under uniform guidance cost principles. Views of Responsible Officials and Planned Corrective Actions - The University believes that the $141,477 transaction noted as a Questioned Cost properly met the conditions to be considered an allowable cost of the grant. The cited payments were made to two separate groups (third party housing contractor and University students in said contractor provided housing) related to the closing of the University during the spring 2020 term due to COVID 19 restrictions. After multiple layers of review, the University determined that these two payments covered two distinct types of losses (refund of housing fees to students required to leave housing and payment to housing contractor for loss of contracted housing revenue) as a direct result of the University's closure due to COVID 19 restrictions. To resolve the issue and for future reference, the University will be providing details of the transactions to the Department of Education (ED) requesting a determination of the allowability of the questioned costs. The University will continue to refer to the Higher Education Relief Education Fund (HEERF) FAQs, follow ED guidance and continue to require a review and approval by appropriate management of all costs charged to the grant. The University will also require a review and approval by both the Controller and Vice President for Finance and Administration of all future lost revenue calculations prior to reporting these costs against the grant.

Assistance Listing Number, Federal Agency, and Program Name - ALN Nos. 84.063 and 84.268; Department of Education; Federal Pell Grant Program and Federal Direct Loan Program. Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. (34 CFR 668.173(b)) Condition - The University did not return Title IV funds to the Department of Education (ED) within the required timeframe for certain students who required a return of funds. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 withdrawn students tested for proper return of Title IV, funds for 6 students requiring a return were not returned by the University to ED within the required timeframe. Cause and Effect - The University had a change in personnel in the financial aid department and did not have a process in place to ensure calculations performed were processed and returned to ED within the required timeframe, which led to returns of Title IV funds to ED to be completed outside the required timeframe. Recommendation - We recommend that the University institute a process to ensure that all returns of Title IV aid are calculated and returned within the required timeframe. Views of Responsible Officials and Planned Corrective Actions - Reports will be run each week to identify withdrawn students with federal financial aid. R2T4 calculations will be completed. Common Origination and Disbursement (COD) exports will be run each day. COD will be monitored to ensure returns are being completed in a timely manner.

CFDA Number, Federal Agency, and Program Name - CFDA Nos. 84.007, 84.033, 84.063, 84.268, 84.379; Department of Education; Federal Supplemental Educational Opportunity Grants, Federal College Work Study, Federal Pell Grant Program, Federal Direct Loan Program, Teacher Education Assistance for College and Higher Education (TEACH) Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. The policy provides that a student's academic progress is evaluated at the end of each payment period or at least annually to correspond with the end of a payment period; (34 CFR 668.34(a) and (a)(1)(3)(i)). Condition - Satisfactory academic progress status was not updated for students at the end of the 2020 spring academic term. Questioned Costs - $9,272 Identification of How Questioned Costs Were Computed - Students that should have been in suspension status as of the end of the academic year and received aid for summer term 2020 during the year ended June 30, 2020. Context - Of the 25 students tested for proper review of satisfactory academic progress, 1 student was identified that did not have the correct satisfactory academic progress reported at the end of Spring 2020 based on the University satisfactory academic progress policy. The satisfactory academic progress was not updated in the system for all students based on a system issue. As a result there was $9,272 of aid improperly disbursed for summer 2020 term for students that should have been in a suspension status and not eligible for financial assistance. Cause and Effect - Shawnee State University did not have proper controls in place to ensure that satisfactory academic progress status is updated for all students each term. As a result, satisfactory academic progress was not properly updated for Spring 2020. Recommendation - Shawnee State University should implement controls and processes to ensure that satisfactory academic progress status is updated for all students each term. Views of Responsible Officials and Planned Corrective Actions - After the SAP process has been completed, the Financial Aid Office will run a report to identify any students who should have had their status updated. The incorrect statuses will be updated.

CFDA Number, Federal Agency, and Program Name - CFDA Nos. 84.063, 84.268; Department of Education; Federal Pell Grant Program and Federal Direct Student Loans Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes 2019 002 Criteria - Federal Pell Grant Program: An institution shall submit, in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct (34 CFR Section 690.83(b)(2)). Federal Direct Student Loans: Changes in student status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change (34 CFR Section 685.309(b)). Condition - Shawnee State University did not report the proper student status changes for certain students who graduated. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested for student status changes, 2 students were not properly reported as graduated. These students had previously ceased enrollment at the University and were reported as a withdrawal to NSLDS, but subsequently petitioned and received approval to graduate. Cause and Effect - Shawnee State University did not have proper controls in place to ensure that students that were no longer enrolled at the University and received approval to graduate were properly reported as graduated to NSLDS. Recommendation - Shawnee State University should implement controls and processes to ensure that all students that receive approval to graduate are reported to NSLDS. Views of Responsible Officials and Corrective Action Plan - The Registrar?s Office will run a report at the end of each term to identify students who graduated without taking a course that semester. This will identify those students who need reviewed to ensure their status was reported to the Clearinghouse correctly.

CFDA Number, Federal Agency, and Program Name - CFDA Nos. 84.063, 84.268; Department of Education; Federal Pell Grant Program and Federal Direct Student Loans. Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria- Federal Pell Grant Program: An institution shall submit, in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct (34 CFR Section 690.83(b)(2)). Federal Direct Student Loans: Changes in student status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change (34 CFR Section 685.309(b)). Condition - Shawnee State University did not report the proper student status changes for certain students that graduated. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested for student status changes, two students were not properly reported as graduated. Cause and Effect - Shawnee State University did not have proper controls in place over the graduate file submission to the National Student Clearinghouse to ensure that students were appropriately reported to NSLDS. Recommendation - Shawnee State University should implement controls and processes to ensure that graduation files submitted are complete and are properly reported to NSLDS. Views of Responsible Officials and Corrective Action Plan - Based on discussions with the National Student Clearinghouse personnel, the Registrar?s Office will begin sending a graduates-only enrollment file in addition to the degree verification file the University has been sending in the past. This additional file should resolve the issue of graduation status not being sent from the National Student Clearinghouse to NSLDS. Moving forward, a member of the registrar's office will review all file submissions to ensure graduation statuses are reported correctly.

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