LAWRENCE TECHNOLOGICAL UNIVERSITY

Assistance Listing Number, Federal Agency, and Program Name Research and Development Cluster National Science Foundation, Department of Commerce, Department of Health and Human Services, Department of Energy, National Endowment for the Humanities, and Department of Transportation ALN 47.083, 47.041, 47.070, 47.084, 47.049, 11.024, 12.RD, 93.884, 93.113, 81.089, 59.065, 81.010, 81.RD, 45.129, 12.600, 59.059, 20.200, 20.505 Federal Award Identification Number and Year Various Pass through Entity Various Finding Type Significant deficiency Repeat Finding No Criteria According to 2 CFR 200.313(d)(2), a physical inventory of the property must be conducted and the results must be reconciled with the property records at least once every two years. Condition The University did not complete a physical inventory of the property within the last two years. Questioned Costs None If Questioned Costs are not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could not be Reported N/A Identification of How Questioned Costs Were Computed N/A Context The University did not complete a physical inventory of the property within the last two years. Cause and Effect Policies in place did not include a control to ensure a physical inventory of property is completed at least once every two years. Recommendation The University should implement controls to ensure a physical inventory of property is completed at least once every two years. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. Management will establish a formal inventory schedule that mandates physical inventory and reconciliation at least once every two years. Designated personnel will be assigned responsibility for executing and documenting the inventory process. Additionally, internal controls will be enhanced through periodic monitoring and reminders to ensure timely completion and proper record keeping.

Assistance Listing Number, Federal Agency, and Program Name Research and Development Cluster National Science Foundation, Department of Commerce, Department of Health and Human Services ALN 47.070, 11.024, , 93.113 Coronavirus State and Local Fiscal Recovery Funds Program ALN 21.027 Federal Award Identification Number and Year Various (R&D) and 21.027 Pass through Entity Various (R&D) and City of Southfield, Michigan; United Way for Southeastern Michigan; MEDC (21.027) Finding Type Significant deficiency Repeat Finding No Criteria A nonfederal entity must conduct all procurement transactions in a manner providing full and open competition in accordance with 2 CFR Section 200.319. Condition The University supported full and open competition when testing Research and Development procurement contracts but did not support rationale for utilizing the selected contractor for 12 of the 23 samples tested. The University supported full and open competition when testing Coronavirus State and Local Fiscal Recovery Funds procurement contracts but did not support rationale for utilizing the selected contractor for 5 of the 5 samples tested. Questioned Costs None If Questioned Costs are not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could not be Reported N/A Identification of How Questioned Costs Were Computed N/A Context While the University utilized full and open competition in its procurement process, it did not consistently retain documentation explaining the rationale for selecting specific contractors. Cause and Effect The absence of documented rationale for contractor selection may reflect a focus on meeting competition requirements without fully capturing decision making details. This can make it more difficult to demonstrate the basis for contractor choice and ensure clarity in the procurement process. Recommendation The University should enhance its procurement documentation practices by consistently recording the rationale for contractor selection. This will help ensure transparency, support future reviews, and demonstrate alignment with competitive procurement principles in accordance with 2 CFR Section 200.319. Views of Responsible Officials and Planned Corrective Actions Management will reinforce its existing procurement procedures to ensure that competitive selections are not only conducted appropriately but also consistently documented. Management will implement a standardized documentation protocol that captures the rationale, evaluation criteria, and selection process for each procurement decision. The Procurement Policy will be revised, training will be provided to relevant staff, and periodic reviews will be conducted to ensure compliance.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, Federal Work Study Program ALN 84.033, Federal Perkins Loan Program ALN 84.038, and Federal Supplemental Educational Opportunity Grant (FSEOG) ALN 84.007. Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes 2023-003 Criteria - Institutions must address safeguards within their written information security program (16 CFR 314.4). The institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). Condition - The University does not have all of the minimum safeguards written down within its information security program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the seven minimum elements required to be written in the information security program, the University did not have one of them. The University did not have all of the required safeguards written within their information security program. Cause and Effect - The University does not have adequate controls or processes in place to ensure safeguard policies are documented. Recommendation - The University should implement controls to ensure minimum required elements, including the safeguards, are incorporated into written policies. Views of Responsible Officials and Corrective Action Plan - This finding has already been addressed. During the current year testing, we updated our “GLBA Information Security Program”. While it does contain all elements required, technically the policy was not updated until 7/25/2024. LTU followed up with the FSA Cyber Compliance Team regarding this finding from last year. We received the following response on August 15th, 2024: Thank you for providing evidence artifacts to the Federal Student Aid (FSA) Cybersecurity Compliance Team indicating that you have satisfied the minimum information security requirements of Gramm-Leach-Bliley Act (GLBA) at Lawrence Technological University for the audit year of 2023. As a courtesy, we remind you that all the GLBA Cybersecurity requirements are to be satisfied each audit year. Protecting student data is an utmost priority for FSA and we are committed to ensuring the safety and security of student information. We have reviewed the information you provided and determined it sufficient to close the case.

Assistance Listing Number, Federal Agency, and Program Name ‑ Department of Education ‑ Education Stabilization Fund ‑ Higher Education Emergency Relief Fund ‑ Institutional ‑ ALN 84.425F Federal Award Identification Number and Year ‑ P425E2000493, 6/30/2023 Pass‑through Entity ‑ N/A Finding Type ‑ Significant deficiency Repeat Finding ‑ Yes ‑ 2022‑001 and 2021‑001 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 requires quarterly public reporting of both student portion and institutional portion awards. Condition ‑ The institutional report for the quarter ended September 30, 2022 was inaccurate. Questioned Costs ‑ None Identification of How Questioned Costs Were Computed ‑ N/A Context ‑ There was one quarter identified where the University inaccurately completed the institutional quarterly report. Cause and Effect ‑ The University did not track all requirements and expenditures accurately to ensure that the quarterly public reporting was completed properly and accurately. Recommendation ‑ We recommend the University implement controls to ensure that all quarterly expenditure reports are tracked for proper reporting requirements and correct expenditures. Views of Responsible Officials and Planned Corrective Actions ‑ The University has completed using all HEERF funds and has closed reporting to them. No further reports will be required.

Assistance Listing Number, Federal Agency, and Program Name ‑ Department of Education ‑ Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year ‑ Various Pass‑through Entity ‑ N/A Finding Type ‑ Significant deficiency Repeat Finding ‑ Yes ‑ 2022‑004, 2021‑004, 2020‑004, and 2019‑001 Criteria ‑ Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition ‑ The University did not report certain students' status to NSLDS in a timely manner during the fiscal year. Questioned Costs ‑ None Identification of How Questioned Costs Were Computed ‑ N/A Context ‑ Of the 31 students tested, there were 6 students whose status changes were not reported to the NSLDS within 60 days. Cause and Effect ‑ The University does not have adequate controls or processes in place to ensure status changes are reported to the NSLDS timely. As a result, certain student status changes were not reported timely to the NSLDS. Recommendation ‑ The University should implement controls to ensure student status changes are reported timely to the NSLDS. Views of Responsible Officials and Planned Corrective Actions ‑ The University team will review status updates for all students that continue enrollment from one semester to another (May to summer) to be sure their previous and new status both appear in NSLDS. All the students that were identified had continued with a new degree program in the summer, so the corrective action plan we are implementing will catch any issue before their new enrollment information is updated to NSLDS.

Assistance Listing Number, Federal Agency, and Program Name ‑ Student Financial Assistance Cluster ‑ Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, Federal Work‑Study Program ALN 84.033, Federal Perkins Loan Program ALN 84.038, and Federal Supplemental Educational Opportunity Grant (FSEOG) ALN 84.007 Federal Award Identification Number and Year ‑ Various Pass‑through Entity ‑ N/A Finding Type ‑ Significant deficiency Repeat Finding ‑ No Criteria ‑ Institutions must address safeguards within their written information security program (16 CFR 314.4). The institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). Condition ‑ The University does not have all of the minimum safeguards written down within its information security program. Questioned Costs ‑ None Identification of How Questioned Costs Were Computed ‑ N/A Context ‑ Of the seven minimum elements required to be written in the information security program, the University did not have one of them. The University did not have all of the required safeguards written within their information security program. Cause and Effect ‑ The University does not have adequate controls or processes in place to ensure safeguard policies are documented. Recommendation ‑ The University should implement controls to ensure minimum required elements, including the safeguards, are incorporated into written policies. Views of Responsible Officials and Corrective Action Plan ‑ The University does have information security controls in place. While we have implemented these controls and safeguards, we acknowledge they are not documented in our formal policies. Our corrective action is to have these controls formalized and documented in the coming year.

Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Higher Education Emergency Relief Fund - Institutional - ALN 84.425F Federal Award Identification Number and Year - P425F201211 Pass - through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes 2021-001 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 timely file Institutional HEERF quarterly reporting for the quarter ended June 30, 2021 and the Institutional report for the quarter ended September 30, 2021 was inaccurate. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There was one instance identified where the University did not timely file the institutional HEERF quarterly report and one instance where the University inaccurately completed the institutional quarterly report. 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 accurately and 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 submit completely and accurately. Views of Responsible Officials and Planned Corrective Actions - When future reporting is required, the director of financial aid will review criteria against requirements and due dates and pass to the operation manager in financial aid and to the student accounting supervisor for a second review of content and due dates.

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster - National Science Foundation Computer and Information Science and Engingeering, Department of Education State Energy Program, Department of Commerce Economic Adjustment Assistance - ALN 47.070, 81.041, 11.307 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity must conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition - The University could not support full and open competition for 10 of the 18 samples tested. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The University utilized recommended or existing vendors and could not evidence full and open competition existed prior to selection of the vendor. Cause and Effect - Purchasing policies in place are not followed in all circumstances. For expenditures at or below certain thresholds, project investigators have the ability to circumvent controls and contract with vendors and/or make purchases prior to receiving necessary approvals. Recommendation - The University should implement controls to ensure all grant funded expenditures are appropriately subject to full and open competition, in accordance with 2 CFR section 200.319, and conclusions to award contracts are memorialized. Views of Responsible Officials and Planned Corrective Actions - Management will revise its Procurement Policy to require documentation supporting the rational for why a noncompetitive bid is utilized in a procurement decision using federal funds.

Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes - 2021-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended)(34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. (34 CFR Section 668.22). Post withdrawal disbursements must be made from available grant funds before available loan funds (34 CFR 668.22(a)(6)). Post withdrawal disbursements of grant funds may be credited to the student?s account, without the student?s authorization, for current year outstanding charges for tuition, fees, and room and board (if contracted with the institution) on the student?s account, up to the amount of those outstanding charges. For current year outstanding charges other than tuition, fees, and room and board (if contracted with the institution), the institution must have the student?s authorization to credit the student?s account with grant funds. Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the withdrawal date required to be used based on federal regulations. The discrepancies in withdrawal dates resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not complete Title IV calculations based on federal regulations which resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not obtain student authorization prior to crediting student account for post withdrawal disbursement. Questioned Costs - $4,244 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were four errors that attributed to this finding: 1) Of the 21 students tested, there were 4 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $2,675 in questioned costs. 2) Of the 21 students tested there were 2 students identified where the University did not calculate the R2T4 correctly resulting in $1,569 in questioned costs. 3) Of the 21 students tested there were 5 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 4) Of the 21 students tested there was 1 student identified where the University did not obtain authorization from student prior to crediting account for post withdrawal disbursement. Cause and Effect - The University did not have a control in place to ensure all Title IV calculations, Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Recommendation - The University should implement controls to ensure all Title IV calculations, returns of Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Views of Responsible Officials and Corrective Action Plan - One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly.

Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes - 2021-004, 2020-004 and 2019-001 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were two errors identified that attributed to this finding. 1) Of the 40 students tested, there was 3 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2) Of the 40 students tested, there were 2 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. Cause and Effect - The University does not have adequate controls or processes in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of student campus and program level reporting. Views of Responsible Officials and Planned Corrective Actions - A new position was formed with the Title Assistant Registrar for Special Program and Compliance. This position was officially hired on January 11, 2022. They have gone through training for both NSC and NSLDS. They will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports.

Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Higher Education Emergency Relief Fund - Student - ALN 84.425E Federal Award Identification Number and Year - P425E2000493 Pass through Entity - N/A Finding Type - Significant deficiency 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 timely file Student HEERF quarterly reporting for the quarter ended December 31, 2020 and Institutional reporting for quarter ended March 31, 2021. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There was one instance identified where the University did not timely file the student HEERF quarterly report and the institutional quarterly report. 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 - When future reporting is required, the Director of Financial Aid will review criteria against requirements and due dates and pass to the Operation Manager in Financial Aid and to Student Accounting Supervisor for a second review of content and due dates.

Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Perkins Loan Program ALN 84.038 Federal Award Identification Number and Year - P038A172032 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Institutions must retain true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan (including Defense, NDSL) made. Disbursement records, electronic authentication and signature records for loans made with an MPN must also be retained by the institution. Institutions are required to keep original paper promissory notes or original paper MPNs and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. An institution shall retain disbursement and electronic authentication and signature records for each loan made using an MPN for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. When an institution uses a third party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third party servicer is in compliance with the requirements for the functions the third party servicer is performing for the school. Such due diligence could include obtaining and reviewing the third party servicers most recent Title IV compliance audit. (34 CFR 674.19.(e).) Condition - Of the 25 students tested, 1 was student was identified to not have a master promissory note on file. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There was one instance identified where the University and its third party loan servicer, UAS, could not locate the master promissory note for a student. Cause and Effect - The University did not have an effective control in place to ensure that open Perkins loan master promissory notes are kept for the required timeframe. Recommendation - The University should implement controls to ensure Perkins master promissory notes are kept. Views of Responsible Officials and Planned Corrective Actions - All Perkins Loan borrowers must complete an MPN in order to take out the Perkins Loan. Older Perkins MPNs were paper documents, stored in a fireproof filing cabinet. More recent Perkins MPNs have been electronic documents, stored on a UAS (University Accounting Service) site. MPNs are pulled, either from the filing cabinet or the UAS site, when a Perkins Loan is paid in full. The original goes to the borrower and LTU saves a copy. If an MPN cannot be located and it is paid in full, then they are notified that their Perkins Loan is paid in full and are not given the original MPN. If the Perkins Loan is defaulted two years or more, then LTU would have to write off the loan.

Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date. (34 CFR Section 668.22). Condition - Of the 17 students selected for Return to Title IV testing, the University used the incorrect withdrawal date for 1 student. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There was one instance identified where a student withdrew from all eligible courses but had the wrong withdrawal date used in the return of title IV funding calculation. This was due to a data entry error. The calculation was eventually corrected by the University, as such, there are no questioned costs. Cause and Effect - The University does not have an effective control inplace to ensure that correct withdrawal dates are used in Return to Title IV calculations. Recommendation - The University should implement review procedures to verify that the correct withdrawal dates have been used in the Return to Title IV calculations Views of Responsible Officials and Planned Corrective Actions - After the student?s SFAREGS is updated and the SFRWDRL process is run, the dates are reviewed a second time to validate that the correct dates were used. This is done by the Office of the Registrar. Once the dates are validated, the reports are forwarded to the Office of Financial Aid to process Title IV.

Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes 2019 001, 2020 004 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - Of the 40 students tested, 6 students were identified with either incorrect effective dates related to a status change or whose status changes were not reported to the NSLDS accurately at both the campus and program level. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were two types of enrollment reporting issues identified: 1) Of the 40 students tested, there were 5 students who were accurately reported, however, they did not have their graduation status reported timely to the NSLDS. 2) Of the 40 students tested, there was 1 student that had the incorrect date reported. Cause and Effect - The University does not have adequate controls or processes in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of student campus and program level reporting. Views of Responsible Officials and Planned Corrective Actions - We are hiring a new person with the title of Assistant Registrar for Special Programs and Compliance. This person is already working in the Office of the Registrar. She has access to NSC and now NSLDS. She is being trained on what to look at in NSLDS for both the campus and program level. Part of her responsibilities will be to validate data in NSLDS to be sure the correct information is flowing from NSC to NSLDS. A report will be created that identifies Title IV students that have a status change. It will then be validated in NSLDS. Once a student graduates, she will validate that the information flowed correctly to NSLDS at the program level.

CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster CFDA No. 84.268 Federal Direct Student Loans, and 84.007 Federal Supplemental Education Opportunity Grant Program Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - The University has 45 days from the date the University determines a student?s withdrawal date to calculate a return to Title IV refund calculation for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdraws or expresses notification to withdraw or, if the student does not officially withdraw, the date that the University determines the student is no longer in attendance (34 CFR Section 668.73(b)). Condition - Of the 16 students selected for return to Title IV testing, the University did not return the funds of 1 student within 45 days of becoming aware that the student had withdrawn from classes. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There was one instance identified where a student withdrew from all eligible credit courses in the fall semester of 2019 but did not have a return of Title IV refund calculation performed within the required time frame. This was due to the student remaining enrolled in a noncredit course for the semester that was not eligible for Title IV aid. Cause and Effect - The University did not have the proper control in place to ensure students who withdraw from all eligible credit courses but remain in a non credit eligible course have a return to Title IV refund calculation performed in a timely manner. Recommendation - The University should consider implementing review procedures to verify that all students needing calculations have been identified. Views of Responsible Officials and Corrective Action Plan - A report has been developed by the Office of the Registrar to capture/identify students who have withdrawn/failed coursework and remain enrolled in a non credit hour course. This is an automated report and is generated weekly. The Office of the Registrar and Office of Financial Aid return to Title IV processors receive a copy of the report.

CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster CFDA No. 84.063 Federal Pell Grant Program Federal Award Identification Number and Year - Various Pass through Entity - NA Finding Type - Significant deficiency Repeat Finding - No Criteria - The University must disburse the appropriate amount of federal aid based on the student?s enrollment status and expected family contribution (EFC) 34 CFR Section 690.62 (a). The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the secretary for each award year. Condition - For 1 of the 23 students selected for testing, the Pell Grant amount awarded and disbursed did not agree to the payment and disbursement schedule. It was identified that this impacted 1 additional student not included in the original sample of 23 students. Questioned Costs - $2,050 Identification of How Questioned Costs Were Computed - The amount of questioned costs was calculated by determining the difference between the amount disbursed to the students and the amount of the award per the Pell Grant payment schedule. Context - For 1 of the 23 students selected for testing, the Pell Grant amount awarded and disbursed did not agree to the payment and disbursement schedule. This was determined to be due to the amount of the award not being updated after the student's verification process was completed, where the EFC amount changed based on the income obtained during the verification process. The University identified that this impacted one additional student during the year. Both students were under awarded and subsequently were provided the proper Pell Grant amounts. Cause and Effect - The University did not have the proper control in place to ensure students who had a change in their EFC as the result of being verified received the proper amounts of Pell Grant for the academic year. Recommendation - The University should consider implementing review procedures to verify that all students who have completed the verification process have had their awards updated. Views of Responsible Officials and Planned Corrective Actions - A new report was created to indicate when a student has a change in EFC. Those students will then be repackaged to ensure they are awarded proper Pell Grant values based on the Pell Grant schedule according to their EFC.

CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster CFDA No. 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes - 2019-001 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - Of the 40 students tested, 4 students were identified with either incorrect effective dates related to a status change or whose status changes were not reported to the NSLDS accurately at both the campus and program level. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context There were three types of enrollment reporting issues identified: 1) Of the 40 students tested, there was 1 student who decreased from full time to half time in the fall 2019 semester whose status change effective date was not accurately reported to the NSLDS at the program level. 2) Of the 40 students tested, there were 2 students who did not have their graduation status reported to the NSLDS at the program level. 3) Of the 40 students tested, there was 1 student who did not have their graduation status reported to the NSLDS at the campus level. Cause and Effect - The University does not have a control or process in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of student campus and program level reporting. Views of Responsible Officials and Planned Corrective Actions - The University will review the data submissions schedules with both the National Student Clearinghouse (NSC) and NSLDS. The registrar will have data reviewed from NSC to NSLDS to be sure the data has updated correctly in all areas. When making corrections to NSC that feed to NSLDS, the registrar is now aware that it requires the updates to be done in two separate areas. This has been noted as part of corrections to NSC for future corrections.

CFDA Number, Federal Agency, and Program Name - COVID-19 - Education Stabilization Fund - CFDA No. 84.425E Federal Award Identification Number and Year - P425E200493 Pass through Entity - NA Finding Type - Significant deficiency Repeat Finding - No Criteria - On May 6, 2020, the Department of Education posted an electronic announcement (which was subsequently updated on August 31, 2020 through a Federal Register posting) that required institutions that received a HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their websites in a format and location that is easily accessible to the public 30 days after the date when the institutions received their allocations under 18004(a)(1). Condition - The report dated May 18, 2020 uploaded to the University's website did not include two of the items identified as critical information to be included within the report. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Upon review of the information reported by the University, it was identified that the University did not include in the report two of the items identified as critical information in its report dated May 18, 2020, which included: -The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of the submission. -The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act. Cause and Effect - The University did not have a procedure in place to ensure that the required critical information was included within its report. Recommendation - The University should implement a procedure to ensure all required data and information is included in reports required to be made for federal awards. Views of Responsible Officials and Planned Corrective Actions - When future reporting is required, the director of financial aid will review criteria against requirements, then pass information to the president of finance for a second procedural review. Information required on the website will also be submitted to the director of web services for a third review before the required information is put on the university website.

CFDA Number, Federal Agency, and Program Name- Student Financial Aid Cluster - CFDA No. 84.268 Federal Direct Loans and 84.063 Federal Pell Grants Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Appendix C of the NSLDS Enrollment Reporting Guide defines a withdrawn (voluntary or involuntary) student as a student who has officially withdrawn from all courses, stopped attending all classes but did not officially withdraw, or who for any reason did not re- enroll for the next regular (non-summer) term without completing the course of study. The effective date is the date the student officially withdraws or, in the absence of a formal withdrawal, the last recorded date of attendance. In the case of the student who completes a term and does not return for the next term, leaving the course of study uncompleted, the effective date for the withdrawn status is the final day of the term in which the student was last enrolled. Condition - Of the 40 students tested, two students' status changes were not reported to the NSLDS in a timely manner. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there was 1 student who unofficially withdrew in the spring 2019 semester whose status change was submitted to the NSC, but the change was not received by the NSLDS. There was another student whose withdrawn status was not reported to the NSLDS within 60 days of being withdrawn from the University while the University was working to confirm the graduation status. Cause and Effect - The University does not have a control or process in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. In both cases the University properly updated the students' record in the NSLDS; however, the communication was not timely. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of students who graduated or unofficially withdrew. Views of Responsible Officials and Corrective Action Plan - The University concurs with the findings and recommendations. To address the instances of noncompliance within the finding the University with do the following: The sequence order of processing will be changed to capture the required information after the semester ends to submit to the National Student Clearinghouse (NSC). The end-of-term processing will take place, eligible F grades will be converted to WF grades, the Title IV processing will be conducted, and then the final submission to the NSC will occur. This will ensure that the final change of status is recorded to the NSC to be reported to NSLDS in a timely manner. Graduates will be reported to NSC as withdrawn at the next NSC submission after the semester ends. Once the graduation process has been completed, the W (withdrawn) status will be changed to the status of G (graduated) in the NSC. This will ensure that we are reporting data to the NSC to be reported to NSLDS in a timely manner.

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