Ashland University

Identification of the federal program and specific federal award: i. Assistance listing title and number: Student Financial Assistance - Cluster, Federal Pell Grant (Pell) - 84.063 ii. Federal award identification number and year: P063P210331, 2021 - 2022 Federal Award Year iii. Name of federal agency: U.S. Department of Education iv. Name of the applicable pass-through entity: Not applicable b. Criteria or specific requirement (including statutory, regulatory or other citation): An institution shall, upon receipt of an Enrollment Reporting roster file from the Secretary of the U.S. Department of Education (ED) (Secretary), complete and return that report within 30 days of receipt. Unless the institution expects to submit its next enrollment report to the Secretary within the next 60 days, the institution must notify the Secretary or the lender within 30 days if: the institution discovers that a federal loan has been made to or on behalf of a student who enrolled at that school but who has ceased to be enrolled on at least a half-time basis; the institution discovers that a federal loan has been made to or on behalf of a student who has been accepted for enrollment at that school but who failed to enroll on at least a half-time basis for the period for which the loan was intended; or the institution discovers that a student who is enrolled has changed his or her permanent address. See 34 C.F.R. § 685.309(b). c. Condition: The University was required, as a result of the Focused Program Review (OPE ID: 00301200) (FPR) regarding its participation in the “Pell for Students Who Are Incarcerated” experiment (Second Chance Pell), to complete a full file review (enrollment status, effective dates, reporting dates) of all National Student Loan Data System (NSLDS) enrollment reporting for the 2019-20 and 2020-21 award years, and update and correct errors identified. Cause: ED, as a result of the FPR and the findings contained within the Final Program Review Determination (FPRD) on September 16, 2022, required the University to update its enrollment data to correct certain errors. e. Effect or potential effect: The enrollment data for the University’s students in the NSLDS was deemed to be inaccurate by ED. f. Questioned costs: There are no questioned costs associated with this finding. g. Context: This matter arose as a result of the FPR and findings contained within the FPR and ED’s determination that data needed to be corrected. The University commenced the process to correct the data subsequent to the issuance of the FPRD and completed this process subsequent to May 31, 2023. h. Identification as a repeat finding, if applicable: This is a repeat finding of Finding 2023-001. i. Recommendation: We recommend the University review its policies and procedures to ensure that there are timely and complete submissions to the NSLDS, and that training occur for those individuals who are involved in the uploading of enrollment data to the NSLDS. j. Views of responsible officials: Management concurs with the finding. The Registrar’s Office has performed a further review of its policies and procedures to continue to ensure timely, accurate and complete submissions to the NSLDS. A how-to manual has been developed and training has occurred and regular training cadence has been developed utilizing training resources provided by associations and the U.S. Department of Education. The required corrections were completed on September 30, 2024.

The Registrar's Office has performed a further review of its policies and procedures to continue to ensure timely, accurate, and complete submission of enrollment records. The Registrar’s Office has updated its procedures to include response schedules with internal control mechanisms for monitoring compliance with the seven-day response requirement to the Provost’s Office and processing requests for additional assistance as necessary. The updated response schedule includes a goal to respond to error reports within four days of receipt, with final submission no later than six days following notice of the error report, unless the Provost has been notified that enrollment updates have been suspended by National Student Clearinghouse while files are being processed, in which case the Registrar’s Office will monitor and document the processing status until the suspension has been raised. Any response which will exceed six days requires written notice to the Provost’s Office with a plan to complete the required enrollment updates by 5:00pm ET on the seventh day, and any request for additional assistance or resources necessary to do so. Members of the Registrar’s Office also participated in additional training through National Student Clearinghouse with respect to enrollment reporting and error report codes related to enrollment effective dates. Training related to enrollment reporting will be scheduled at least annually through the Registrar’s Office. Finding 2022-005 of the Final Audit Determination (FAD) found that student enrollment status effective dates required further updates following the initial data corrections which were completed in September 2023. In addition to review of its policies and procedures and training, the Registrar’s Office engaged with its third-party servicer for enrollment reporting to review the data reporting systems and integration, as well as the data and information reported by the servicer to the National Student Loan Data System (NSLDS), during its response to Finding 2022-005. In response to the required action for this finding, the University requested an extension and the extension was granted to complete the required action with the U.S. Department of Education Office of Federal Student Aid (FSA). FSA requested regular status reporting and the University complied with the reporting requirement. The status reporting included updates as to the progress of the review and the University’s methods for reviewing and updating the enrollment reports so that FSA could ensure timely and accurate progress was being achieved throughout the University’s completion of the required action. The University completed the required corrections within the extension timeline of September 30, 2024.

2023-001

Finding 2023-001: a. Identification of the federal program and specific federal award: i. Assistance listing title and number: Student Financial Assistance - Cluster, Federal Pell Grant (Pell) - 84.063 ii. Federal award identification number and year: P063P210331, 2021 - 2022 Federal Award Year iii. Name of federal agency: U.S. Department of Education iv. Name of the applicable pass-through entity: Not applicable b. Criteria or specific requirement (including statutory, regulatory or other citation): An institution shall, upon receipt of an Enrollment Reporting roster file from the Secretary of the U.S. Department of Education (ED) (Secretary), complete and return that report within 30 days of receipt. Unless the institution expects to submit its next enrollment report to the Secretary within the next 60 days, the institution must notify the Secretary or the lender within 30 days if: the institution discovers that a federal loan has been made to or on behalf of a student who enrolled at that school but who has ceased to be enrolled on at least a half-time basis; the institution discovers that a federal loan has been made to or on behalf of a student who has been accepted for enrollment at that school but who failed to enroll on at least a half-time basis for the period for which the loan was intended; or the institution discovers that a student who is enrolled has changed his or her permanent address. See 34 C.F.R. § 685.309(b). c. Condition: The University was required, as a result of the Focused Program Review (OPE ID: 00301200) (FPR) regarding its participation in the “Pell for Students Who Are Incarcerated” experiment (Second Chance Pell), to complete a full file review (enrollment status, effective dates, reporting dates) of all National Student Loan Data System (NSLDS) enrollment reporting for the 2019-20 and 2020-21 award years, and update and correct errors identified. d. Cause: ED, as a result of the FPR and the findings contained within the Final Program Review Determination (FPRD) on September 16, 2022, required the University to update its enrollment data to correct certain errors. e. Effect or potential effect: The enrollment data for the University’s students in the NSLDS was deemed to be inaccurate by ED. f. Questioned costs: There are no questioned costs associated with this finding. g. Context: This matter arose as a result of the FPR and findings contained within the FPR and ED’s determination that data needed to be corrected. The University commenced the process to correct the data subsequent to the issuance of the FPRD and completed this process subsequent to May 31, 2023. h. Identification as a repeat finding, if applicable: This is a repeat finding of Finding 2022-005. i. Recommendation: We recommend the University review its policies and procedures to ensure there are timely and complete submissions to the NSLDS, and that training occur for those individuals who are involved in the uploading of enrollment data to the NSLDS. j. Views of responsible officials: Management concurs with the finding. The Registrar’s Office has performed a review of its policies and procedures to continue to ensure timely, accurate and complete submissions to the NSLDS.

Management concurs with the finding. The Registrar’s Office and Financial Aid Office has performed a review of its policies and procedures and has revised them accordingly to ensure timely, accurate and complete submissions to the NSLDS. The determination of the review was that the enrollment effective status data field required correction in the NSLDS Enrollment History system. Since the restoration of the NSLDS system in November 2022, the Registrar’s Office and Financial Aid has corrected the data which was completed on September 13, 2023.

2022-005

Finding 2022-002: a. Identification of the federal program and specific federal award: i. Assistance Listing title and number: Student Financial Assistance - Cluster, Federal Pell Grant (Pell) - 84.063 ii. Federal award identification number and year: P063P210331, 2021 - 2022 Federal Award Year iii. Name of federal agency: U.S. Department of Education iv. Name of the applicable pass-through entity: Not applicable b. Criteria or specific requirement (including statutory, regulatory or other citation): During the year ended May 31, 2022, the U.S. Department of Education (ED) finalized a Focused Program Review (OPE ID: 00301200) (FPR) regarding the University?s participation in the Experimental Sites Initiative (ESI), which includes the ?Pell for Students Who Are Incarcerated? experiment (Second Chance Pell), by the issuing the Final Program Review Determination (FPRD) on September 16, 2022. The FPR evaluated the University?s compliance with rules and regulations regarding participation in the ESI, specifically the Second Chance Pell program for the 2019-2020 and 2020-2021 federal award years. The FPRD contained certain findings related to the University?s interpretation of and compliance with the Code of Federal Regulations (CFR) and ED?s policies and procedures. ED determined that students who participated in the Second Chance Pell program were not participating in their respective enrolled academic programs in a standard instruction term program, but instead a separate nonstandard instruction term program (Program). During the FPR, ED determined this Program to be less than 30 weeks of instructional time and, as a result, required the University to utilize an alternative payment Formula calculation period for the Federal Pell Grant (Pell). As part of our audit of the University for the year ended May 31, 2022, we considered the results of the FPRD to determine if similar conditions existed for the 2021-2022 federal award year. c. Condition: As part of our audit for the 2021-2022 federal award year, we determined that the University used the same determination for the payment period for those students who had been awarded Pell grants that it had been using in the periods for which ED conducted the FPR. In addition to the population of students who are participating the Second Chance Pell program, the University also identified additional students, that when using ED?s interpretation of the CFR, were utilizing a payment period that did not reflect enrollment in nonstandard instructional term program. d. Cause: As noted in the FRPD, ED indicated that, according to its interpretation of the CFR, students who participate in academic programs with courses that have nonstandard instructional terms should utilize either Pell Formula 2 or 3 to determine the payment period, in accordance with the Federal Student Aid Handbook, Chapter 3 - Calculating Pell and Iraq and Afghanistan Service Grant Awards (Handbook). e. Effect or potential effect: As a result of ED?s determination in the FPRD that during the periods covered by the FPR, students participating in the University?s Second Chance Pell program were enrolled in an academic program utilizing a nonstandard instructional term and the University utilized the same payment formula calculation period for the 2021- 2022 federal award year as it did for the 2019-2020 and 2020-2021 federal award years. In addition to the students who are part of the Second Chance Pell population, when applying ED?s interpretation, the University identified additional students who were participating in nonstandard instructional terms who should also have used Pell Formula 3 as well. As a result, the University removed the amount associated with this finding as allowable Total Federal Expenditures in the accompanying Schedule of Expenditures of Federal Awards (Schedule) for the year ended May 31, 2022. This matter resulted in the qualification of the Independent Auditors? Report on Compliance for Each Major Program and Internal Control Over Compliance for the Student Financial Assistance - Cluster major program for the year ended May 31, 2022, due to the amount of questioned costs and the prevalence of the matters on attributes that are direct and material for this program. This matter impacts the University?s compliance with the Eligibility and Special Tests and Provisions attributes. f. Questioned costs: Management of the University conducted a review of all Pell awarding records for students who were enrolled in nonstandard instructional term programs as determined by ED during the FPR for the 2021-2022 federal award year and compared the amount originally awarded by the University to the amount that would have been awarded using Formula 3, as defined in the Handbook. As a result, questioned costs of $2,329,736 were identified. This amount has been removed as allowable Total Federal Expenditures in the accompanying Schedule for the year ended May 31, 2022. g. Context: For the three semesters included in fiscal year ended May 31, 2022, the University on average served approximately 3,600 incarcerated students enrolled in approximately 26,000 credit hours per semester. This finding impacted 5,687 disbursements for individuals who participated in the Second Chance Pell program during 2021-2022 federal award year, as well as 620 additional disbursements who also participated in other nonstandard instructional term programs. h. Identification as a repeat finding, if applicable: This is not a repeat finding. i. Recommendation: We recommend the University review the instructional period for students participating in the nonstandard instructional term program according to ED?s interpretation and apply the rules regarding the payment period within the Handbook based on the program length. j. Views of responsible officials: Management does not concur with the criteria of this finding due to a disagreement with the interpretation of the regulations included in the FPRD and has appealed the finding as stated in the following paragraphs. Management followed the direction received from the ED Reviewers during the FPR exit interview on September 24, 2021 stating the University should not change its practice for the Second Chance Pell students enrolled in their respective instructional program nor the calculation using Formula 1 for the payment period until the Program Review Report (PRR) is received. The PRR was received on January 3, 2022, which was after the summer and fall 2021 semesters and just weeks prior to the start of the spring 2022 semester. Moreover, pursuant to the Higher Education Act ?498A(b), the University was entitled to an opportunity to review the PRR and, within 60 days of receipt, submit a response for ED?s review prior to it preparing a final determination. The University submitted its response to the PRR on March 11, 2022. The University disagrees with the determinations in the FPRD and is vigorously defending itself against the ED interpretation of the regulations, the findings and the proposed financial assessments. The University filed an appeal of the findings and the associated financial assessments contained in the FPRD on October 24, 2022, and submitted a brief in support of the appeal on January 22, 2023, to the ED Office of Hearings and Appeals within the guidelines as prescribed by the Higher Education Act ? 487(b)(2) and U.S.C. ? 1094(b)(2). Effective with the fall 2022 semester term and with each fall and spring term thereafter, Second Chance Pell students enrolled in their respective instructional programs have a 15 week standard instructional term and the payment period qualifies for calculations utilizing Pell Formula 1.

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-002 Audit Finding: As part of the audit for the 2021- 2022 Federal award year, Schneider Downs determined that the University used the same determination for the payment period for those students who had been awarded Pell grants that it had been using in the periods for which the U.S. Department of Education (ED) conducted the Focused Program Review (FPR). In addition to the population of students who are participating the Second Chance Pell program, the University also identified additional students, that when using ED?s interpretation of the Code of Federal Regulations (CFR), the University used a payment period that did not reflect enrollment in a nonstandard instructional term program. Corrective Actions Taken or Planned: Management does not concur with the criteria of this finding due to a disagreement with the interpretation of the regulations included in ED?s Final Program Review Determination (FPRD) and has appealed the finding as stated in the following paragraphs. Management followed the direction received from the ED Reviewers during the FPR exit interview on September 24, 2021, stating the University should not change its practice for the Second Chance Pell students enrolled in their respective instructional program nor the calculation using Formula 1 for the payment period until the Program Review Report (PRR) is received. The PRR was received on January 3, 2022, which was after the summer and fall 2021 semesters and just weeks prior to the start of the spring 2022 semester. Moreover, pursuant to the Higher Education Act ?498A(b), the University was entitled to an opportunity to review the PRR and within 60 days of receipt, submit a response for ED?s review prior to their preparing a final determination. The University submitted its response to the PRR on March 11, 2022. The University disagrees with the determinations in the FPRD and is vigorously defending itself against the ED interpretation of the regulations, the findings and the proposed financial assessments. The University filed an appeal of the findings and the associated financial assessments contained in the FPRD on October 24, 2022, and submitted a brief in support of the appeal on January 22, 2023, to the ED Office of Hearings and Appeals within the guidelines as prescribed by the Higher Education Act ? 487(b)(2) and U.S.C. ? 1094(b)(2). Effective with the fall 2022 semester term and each fall and spring terms thereafter, the Second Chance Pell students enrolled in their respective instructional programs have a fifteen (15) week standard instructional term and the payment period qualifies for calculations utilizing Pell Formula 1.

Finding 2022-004: a. Identification of the federal program and specific federal award: i. Assistance Listing title and number: Student Financial Assistance - Cluster, Federal Pell Grant (Pell) - 84.063 ii. Federal award identification number and year: P063P210331, 2021 - 2022 Federal Award Year iii. Name of federal agency: U.S. Department of Education iv. Name of the applicable pass-through entity: Not applicable b. Criteria or specific requirement (including statutory, regulatory or other citation): If a student enrolls in a payment period that is scheduled to occur in two award years, the entire payment period must be considered to occur within one award year. The institution must determine for each Federal Pell Grant (Pell) recipient the award year in which the payment period will be placed. If an institution places the payment period in the first award year, it must pay a student with funds from the first award year, and if an institution places the payment period in the second award year, it must pay a student with funds from the second award year. An institution may not make a payment that will result in the student receiving more than 1 ? of his or her scheduled Federal Pell Grant for an award year in accordance with the requirements of 34 C.F.R. ? 690.64(a), (b). c. Condition: The University did not have an established policy and procedure to ensure that it consistently applied the regulations regarding payments of Pell if a student?s program crossed over an award year. d. Cause: The University did not have a formal policy or procedure. e. Effect or potential effect: The University could incorrectly apply the payment rules for student receiving Pell funds. f. Questioned costs: There are no questioned costs associated with this finding. g. Context: Historically, the University has handled this process on a student-by-student basis manually without a formal policy. The University was in the process of formalizing this practice and making certain enhancements to its tracking with its accounting system, but it was not completed until after the 2021-2022 federal award year. h. Identification as a repeat finding, if applicable: This is not a repeat finding. i. Recommendation: We recommend the University establish a formal policy and procedure and ensure that all personnel responsible for the awarding of Pell are trained on how to appropriately follow the policy. j. Views of responsible officials: Management concurs with the finding. In April 2022, a formal policy and procedures addressing the awarding of Pell Grants has been established to ensure compliance, including staff training.

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-004 Audit Finding: The University did not have an established policy and procedure to ensure that the University consistently applied the regulations regarding payments of Pell if a student?s program crossed over an award year. Corrective Actions Taken or Planned: Management concurs with the finding. In April 2022 a formal policy and procedures addressing the awarding of the Pell Grant has been established to ensure compliance including staff training.

Finding 2022-005: a. Identification of the federal program and specific federal award: i. Assistance Listing title and number: Student Financial Assistance - Cluster, Federal Pell Grant (Pell) - 84.063 ii. Federal award identification number and year: P063P210331, 2021 - 2022 Federal Award Year iii. Name of federal agency: U.S. Department of Education iv. Name of the applicable pass-through entity: Not applicable b. Criteria or specific requirement (including statutory, regulatory or other citation): An institution shall, upon receipt of an Enrollment Reporting roster file from the Secretary of the U.S. Department of Education (Secretary), complete and return that report within 30 days of receipt. Unless the institution expects to submit its next enrollment report to the Secretary within the next 60 days, the institution must notify the Secretary or the lender within 30 days if: the institution discovers that a federal loan has been made to or on behalf of a student who enrolled at that school but who has ceased to be enrolled on at least a half-time basis; the institution discovers that a federal loan has been made to or on behalf of a student who has been accepted for enrollment at that school but who failed to enroll on at least a half-time basis for the period for which the loan was intended; or the institution discovers that a student who is enrolled has changed his or her permanent address. See 34 C.F.R. ? 685.309(b). c. Condition: The University was required, as a result of the FPR (OPE ID: 00301200) regarding its participation in the ?Pell for Students Who Are Incarcerated? experiment (Second Chance Pell), to complete a full file review (enrollment status, effective dates, reporting dates) of all National Student Loan Data System (NSLDS) enrollment reporting for the 2019-20 and 2020-21 federal award years, and update and correct errors identified. d. Cause: ED, as a result of the FPR and the findings contained within the FPRD on September 16, 2022, required the University to update its enrollment data to correct certain errors. e. Effect or potential effect: The enrollment data for the University?s students in the NSLDS was deemed to be inaccurate by ED. f. Questioned costs: There are no questioned costs associated with this finding. g. Context: This matter arose as a result of the FPR and findings contained within the FPR and ED?s determination that data needed to be corrected. The University commenced the process to correct the data subsequent to May 31, 2022, however the process of updating the NSLDS enrollment data is still in process as of the date of our report due to the suspension of the NSLDS system and the volume of transactions that must be changed. h. Identification as a repeat finding, if applicable: This is not a repeat finding. i. Recommendation: We recommend the University review its policies and procedures to ensure there are timely and complete submissions to the NSLDS, and that training occur for those individuals who are involved in the uploading of enrollment data to the NSLDS. j. Views of responsible officials: Management concurs with the finding. The Registrar?s Office has performed a review of its policies and procedures to continue to ensure timely, accurate and complete submissions to the NSLDS. The determination of the review was that the enrollment status effective date data field required correction in the NSLDS Enrollment History system. Since the restoration of the NSLDS system in November 2022, the Registrar?s Office has been correcting the data.

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-005 Audit Finding: The University was required, as a result of the Focused Program Review (OPE ID: 00301200) (FPR) regarding the University?s participation in the ?Pell for Students Who Are Incarcerated? experiment (Second Chance Pell), to complete a full file review (enrollment status, effective dates and reporting dates) of all National Student Loan Data System (NSLDS) enrollment reporting for the 2019-20 and 2020-21 award years and update and correct errors identified. Corrective Actions Taken or Planned: Management concurs with the finding. The Registrar?s Office has performed a review of its policies and procedures and has revised them accordingly to ensure timely, accurate and complete submissions to the NSLDS. The determination of the review was that the enrollment effective status data field required correction in the NSLDS Enrollment History system. Since the restoration of the NSLDS system in November 2022, the Registrar?s Office has been correcting the data.

SECTION II - FINANCIAL STATEMENT FINDINGS This section identifies the significant deficiencies, material weaknesses, fraud, noncompliance with provisions of laws, regulations, contracts and grant agreements, and abuse related to the financial statements for which Government Auditing Standards require reporting. There were no findings noted in the current year that are required to be reported in accordance with Government Auditing Standards. SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS This section identifies the audit finding required to be reported by 2 CFR 200.516(a) (significant deficiencies, material weaknesses, material instances of noncompliance, including questioned costs and material abuse). Finding 2020-001: CFDA Numbers: 84.063 and 84.268 Program Names: Federal Pell Grant Program and Federal Direct Student Loans Student Financial Assistance - Cluster, Department of Education Programs Criteria or Specific Requirement: Changes in student status are required to be submitted to the National Student Loan Data System (NSLDS) as required under 34 CFR 690.83(b)(2) for the awards under the Federal Pell Grant Program and 34 CFR 685.309 for awards under the Federal Direct Student Loans Program. Condition: Changes in student status were not submitted within the timeframe specified by 34 CFR 690.83(b)(2) and 34 CFR 685.309. Cause: There was an error in a report, as the report submission did not include the full population of students subject to the requirements for the reporting period. Effect or Potential Effect: As a result of not fulfilling the aforementioned requirements, the University did not comply with the requirements of 34 CFR 690.83(b)(2) and 34 CFR 685.309. Questioned Costs: None noted. Context: Two instances of noncompliance were identified in a sample of 60 students who changed their status during our audit procedures. These instances of noncompliance related to the 2019-2020 federal award year. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University implement procedures to modify the reports to ensure they capture all changes in status for the period to be submitted to NSLDS. In addition, we recommend that a designated individual be responsible for periodic review of the enrollment data and the NSLDS submissions to ensure they are complete and completed within the timeframes specified by 34 CFR 690.83(b)(2) and 34 CFR 685.309. Views of Responsible Officials: Management concurs with this finding. The required policies and procedure for reporting changes in student status to the NSLDS has been expressed and emphasized to the Registrar?s Office staff by providing formal training on January 20, 2021 for current employees, and adding the policy and procedure to new employee training. The Registrar?s Office has implemented a review process for changes in student status reporting to ensure records are properly identified and submitted through the University?s third party, NSLDS, on a timely basis as required by 34 CFR 690.83(b)(2) and 34 CFR 685.309. Effective immediately, on every even month a random sample of changes in student status data will be collected through the University?s student management systems internal reporting; the data will be reviewed by the Registrar for each change in student status report submission to ensure that all records have been appropriately reported; this internal review will be documented and the results retained by the Registrar?s Office on its secure network drive.

Management concurs with the finding. The required policies and procedure for reporting changes in student status to the National Student Loan Data System (NSLDS) has been expressed and emphasized to the Registrar's Office staff by A.)providing formal training on January 20, 2021, for current employees and B.) adding the policy and procedures to new employee training. The Registrar's Office has implemented a review process for changes in student status reporting to ensure records are properly identified and submitted through the University's third party, National Student Loan Data System (NSLDS), on a timely basis as required by 34 CFR 690.83(b)(2) and 34 CFR 685.309. Effective immediately on every even month; A.) a random sample of changes in student status data will be collected through the University's student management systems internal reporting, B.) the data will be reviewed by the Registrar for each change in student status report submission to ensure that all records have been appropriately reported, and C.) this internal review will be documented and the results retained by the Registrar's Office on it secured information technology network drive.

SECTION II - FINANCIAL STATEMENT FINDINGS This section identifies the significant deficiencies, material weaknesses, fraud, noncompliance with provisions of laws, regulations, contracts, grant agreements and abuse related to the financial statements for which Government Auditing Standards require reporting. See Section III - Federal Awards Findings and Questioned Cost for the full context of finding 2019-001, which are both financial statement and federal award findings. SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS This section identifies the audit finding required to be reported by 2 CFR 200.516(a) (significant deficiencies, material weaknesses, material instances of noncompliance, including questioned costs and material abuse). Finding 2019-001 Student Financial Assistance - Cluster, Department of Education Programs Program Names: 84.007 - Federal Supplemental Educational Opportunity Grants, 84.033 - Federal Work-Study Program, 84.038 - Federal Perkins Loan, 84.063 - Federal Pell Grant Program, 84.268 - Federal Direct Student Loans, 84.379 - Teacher Education Assistance for College and Higher Education Grants (TEACH Grants), 93.264 Nurse Faculty Loan Program Criteria or Specific Requirement: Under an institution?s Program Participation Agreement with the Department of Education (Department) and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)) Condition: The University did not have written documentation to demonstrate its compliance with the requirements of 16 CFR 314. Cause: The University has not yet documented a formal risk assessment of its student financial aid security program. Effect or potential effect: If the University does not have a current risk assessment that addresses the three areas noted in 16 CFR 314.4 (b), and documented safeguards for identified risks, there may be inadequate safeguards of student financial aid information. Questioned Costs: None noted. Context: We were unable to verify whether the University had recently performed a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b), and documented safeguards for identified risks, based upon the University?s current operations and environment. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the University perform and document a formal risk assessment that addresses the three areas noted in 16 CFR 314.4 (b), and document safeguards for identified risks. Views of Responsible Officials: Management concurs with this finding. See separate corrective action plan document.

Identifying Number: 2019-001 Audit Finding: The University did not have written documentation to demonstrate its compliance with the requirements 16 CFR 314. Corrective Actions Taken or Planned: Management concurs with the condition, cause and the recommendation as stated in the accompanying schedule of findings and questioned costs. Management will develop a comprehensive risk assessment plan that documents safeguards for each of the identified risks.

GSA_MIGRATION

GSA_MIGRATION

2016-002

GSA_MIGRATION

GSA_MIGRATION

2016-003

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION