Briar Cliff University

Program: Federal Direct Student Loans CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number P268K221428 Federal Award Year: June 30, 2024 Repeat of Prior Year Finding 2024-003 Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: For 10 students tested, the change in enrollment status was not reported to NSLDS within 60 days. For 1 student tested, the enrollment status reported to the National Student Loan Data System (NSLDS) did not match the University’s records during the fiscal year 2025. Question Costs: Not applicable. Context: Noncompliance with federal regulations was noted for 11 of the 40 students who were tested. 10 of the students did not have their change in enrollment status reported to NSLDS within 60 days. 1 student did not show the correct change of status, and thus also did not have their change in enrollment status reported timely to NSLDS. A total of 575 students who were issued Federal Direct Student Loans separated from the University or had a change in enrollment status during fiscal year 2025. The sample was not considered statistically valid. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause: It does not appear that there are proper processes in place surrounding enrollment reporting in order to verify that the correct dates, enrollment statuses, or other information are reported to NSLDS within the required timeframes. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate.

Program: Federal TEACH Grant CFDA Number 84.379 Federal Agency: U.S. Department of Education Federal Award Identification Number: Federal Award Year: June 30, 2024 Criteria: 34 CFR 686.11 states that for the purposes of the TEACH Grant program for an undergraduate student other than a student enrolled in a post-baccalaureate program, has not completed the requirements for a first baccalaureate degree; or for the purposes of a student in a first post-baccalaureate program, has not completed the requirements for a post-baccalaureate program; is enrolled in a TEACH Grant-eligible institution in a TEACH Grant-eligible program; is completing coursework and other requirements necessary to begin a career in teaching or plans to complete such coursework and requirements prior to graduating; and has (A) (1) A final cumulative secondary school grade point average (GPA) upon graduation of at least 3.25 on a 4.0 scale, or the numeric equivalent; or (2) A cumulative GPA of at least 3.25 on a 4.0 scale, or the numeric equivalent, based on courses taken at the institution through the most-recently completed payment period; (B) If the student is beyond the first year of a program of undergraduate education as determined by the institution, a cumulative undergraduate GPA of at least 3.25 on a 4.0 scale, or the numeric equivalent, through the most recently completed payment period; (C) If the student is a graduate student during the first payment period, a cumulative undergraduate GPA of at least 3.25 on a 4.0 scale, or the numeric equivalent; (D) If the student is a graduate student beyond the first payment period, a cumulative graduate GPA of at least 3.25 on a 4.0 scale, or the numeric equivalent, through the most-recently completed payment period; or (E) A score above the 75th percentile of scores achieved by all students taking the test during the period the student took the test on at least one of the batteries from a nationally-normed standardized undergraduate, graduate, or postbaccalaureate admissions test, except that such test may not include a placement test. Condition: For 1 student tested, the student was determined to be ineligible for the TEACH Grant, based on the student GPA and not exceeding the 75th percentile in one ACT area. Question Costs: Not applicable. Context: Noncompliance with federal regulations for 1 of 2 students who were tested for TEACH Grant eligibility. The student was determined to be ineligible for the TEACH Grant. The University distributed the funds to the student during the fiscal year under audit. Subsequent to year end the University returned those funds back to the Department of Education through the G5 portal. A total of 3 students were issued TEACH Grants by the University during fiscal year 2025. Effect: The accuracy of TEACH Grant eligibility is important in determining which students qualify for the grant and if they complete the grant agreement, will not have to pay back the grant. If the student becomes ineligible or changes their mind the grant can be turned into a direct loan. Cause: It does not appear that there are proper processes in place to verify eligibility for TEACH Grants before issuing the Grant to the student account. Recommendation: It is recommended that policies and procedures to verify TEACH Grant eligibility prior to distributing the Grant to a student.

Program: Federal Direct Student Loans CFDA Number 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number P268K221428 Federal Award Year: June 30, 2023 Repeat of Prior Year Finding 2023-004 Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: For 2 students tested, the incorrect enrollment status was reported to the National Student Loan Data System (NSLDS). For 2 students tested, the enrollment status that was reported to NSLDS did not match the University’s records. For 3 students tested, the change of enrollment status was not reported within the 60-day requirement. For 2 students tested, the enrollment status was not updated during the fiscal year 2024. Question Costs: Not applicable. Context: Noncompliance with federal regulations was noted for 9 of the 40 students who were tested. 5 of the students did not have their change in enrollment status reported to NSLDS within 60 days and 4 students did not show the correct change of status, and thus also did not have their change in enrollment status reported timely to NSLDS. A total of 650 students who were issued Federal Direct Student Loans separated from the University or had a change in enrollment status during fiscal year 2024. The sample was not considered statistically valid. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause: It does not appear that there are proper processes in place surrounding enrollment reporting in order to verify that the correct dates, enrollment statuses, or other information are reported to NSLDS within the required timeframes. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within the required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate.

Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Context: Noncompliance with federal regulations was noted for 16 of the 40 students who were tested. 4 Of the students did not have their change in enrollment status reported to NSLDS within 60 days and 12 students did not show the correct change of status, and thus also did not have their change in enrollment status reported timely to NSLDS. In addition, the effective date reported to NSLDS for 4 students did not match the University’s records, and related CIP code reported to NSLDS for 1 student did not match the University’s records. A total of 70 students who were issued Federal Direct Student Loans separated from the University or had a change in enrollment status during fiscal year 2023. The sample was not considered statistically valid. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause: It does not appear that there are proper processes in place surrounding enrollment reporting in order to verify that the correct dates, enrollment statuses, or other information are reported to NSLDS within the required timeframes. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Management’s Response: Briar Cliff will work with Ellucian on a review of the setup and processes that the Registrar’s Office currently follows, and we will work with Ellucian for recommendations on implementing a process/procedure that ensures the Registrar’s Office has been trailed and is in compliance.

Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that 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 begins 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 in accordance with Federal regulations. Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Questioned Costs: The total amount that was remitted to the government that should not have been was $195. Context: Errors were noted in the calculations for 3 of the 8 students selected for testing. There were a total of 71 students who withdrew during fiscal year 2022 that received Title IV aid. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. Cause: The end date of the fall and spring terms were entered incorrectly into the University's software. As such, the total number of days used for the calculations were incorrect, which caused the total amounts calculated to be refunded to also be incorrect. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. This should also include a review of the beginning and ending dates of each term that were entered into the software system. Management's Response: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy.

Finding 2022-005: Perkins Loan Recordkeeping and Record Retention Program: Federal Perkins Loan Program CFDA Number: 84.038 Federal Agency: U.S. Department of Education Federal Award Identification Number: Not applicable Federal Award Year: June 30, 2022 Criteria: 34 CFR 674.19 requires that an institution retains disbursement, electronic authentication and signature records and repayment records, including cancellation and deferment requests for each loan made using a Master Promissory Note (MPN) for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. Condition: For 1 borrower selected for testing, the University was unable to locate the original signed MPN. Questioned Costs: Not applicable. Context: Noncompliance with federal regulations was noted for 1 of the 50 students who were tested. Included in the sample were 25 borrowers with open loans as of May 31, 2022 and 25 borrowers with loans retired or assigned loans within the previous three fiscal years and the current fiscal year. A total of 460 borrowers had outstanding Perkins loan balances as of May 31, 2022 and another 291 borrowers had loans that were retired or assigned within the three previous years and the current fiscal year. The sample was not considered statistically valid. Effect: The University may not have appropriate supporting documentation that the original Perkins loan obligation existed and may not have a legally enforceable claim to collect remaining payments due on the loan. Cause: The original signed MPN was inadvertently disposed of at some point in the past prior to maintaining the documentation for the required time period. Recommendation: We recommend that University review Perkins loan record keeping requirements and double check that all record retention periods have ended prior to disposing of any Perkins loan records. Management's Response: Briar Cliff University has maintained all records related to Perkins loan, even though these loans have been discontinued since September 2017. The University has no intentions to delete or remove any documents until the time is appropriate. The current staff unfortunately was not employed when these records were originally collected or reviewed.

Finding 2022-006: Material Weakness - Federal Direct Student Loan Enrollment Reporting Program: Federal Direct Student Loans CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K221428 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-004 Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: For 12 students tested, the incorrect enrollment status was reported to the National Student Loan Data System (NSLDS). For 21 students tested, the effective date of the change of enrollment status that was reported to NSLDS did not match the University's records. For 11 students tested, the change of enrollment status was not reported within the 60 day requirement. For 6 students tested, in the program-level record, the student's program begin date that was reported to NSLDS did not match the University's records. For 9 students tested, in the program-level record, the program length reported to NSLDS did not match the University's records. For 1 student tested, in the program-level record, the program the student was enrolled in, and the related Classification of Instructional Programs (CIP) code, reported to NSLDS did not match the University's records. Questioned Costs: Not applicable. Context: Noncompliance with federal regulations was noted for 28 of the 40 students who were tested. 11 of the students did not have their change in enrollment status reported to NSLDS within 60 days and 12 students did not show the correct change of status, and thus also did not have their change in enrollment status reported timely to NSLDS. In addition, the effective date reported to NSLDS for 21 students did not match the University's records, the program begin date reported to NSLDS for 6 students did not match the University's records, the program length reported to NSLDS for 9 students did not match the University's records, and the program enrolled, and related CIP code reported to NSLDS for 1 student did not match the University's records. A total of 402 students who were issued Federal Direct Student Loans separated from the University or had a change in enrollment status during fiscal year 2022. The sample was not considered statistically valid. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause: It does not appear that there are proper processes in place surrounding enrollment reporting in order to verify that the correct dates, enrollment statuses, or other information are reported to NSLDS within the required timeframes. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Management's Response: Briar Cliff will work with Ellucian on a review of the setup and processes that the Registrar's Office currently follows and we will work with Ellucian for recommendations on implementing a process/procedure that ensures the Registrar's Office has been trained and is in compliance.

Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires 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. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.

FINDING 2021-004: MATERIAL WEAKNESS ? FEDERAL DIRECT STUDENT LOAN ENROLLMENT REPORTING Program: Federal Direct Student Loans CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K211428 Federal Award Year: June 30, 2021 Repeat of Prior Year Finding 2020-007 Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a halftime basis for the period for which the loan was intended. Condition: For 10 students tested, the incorrect enrollment status was reported to the National Student Loan Data System (NSLDS). For 22 students tested, the effective date of the change of enrollment status that was reported to NSLDS did not match the University's records. For 12 students tested, the change of enrollment status was not reported within the 60 day requirement. For 2 students tested, in the program level record, the student's program begin date that was reported to NSLDS did not match the University's records. For 7 students tested, in the program-level record, the program length reported to NSLDS did not match the University's records. Questioned Costs: Not applicable. Context: Noncompliance with federal regulations was noted for 28 of the 40 students who were tested. 12 of the students did not have their change in enrollment status reported to NSLDS within 60 days and 10 students did not show the correct change of status and thus also did not have their change in enrollment status reported timely to NSLDS. In addition, the effective date reported to NSLDS for 22 students did not match the University's records, the program begin date reported to NSLDS for 2 students did not match the University's records and the program length reported to NSLDS for 7 students did not match the University's records. A total of 620 students who were issued Federal Direct Student Loans separated from the University or had a change in enrollment status during fiscal year 2021. The sample was not considered statistically valid. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause: It does not appear that there are proper processes in place surrounding enrollment reporting in order to verify that the correct dates, enrollment statuses or other information are reported to NSLDS within the required timeframes. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Management?s Response: Management has identified critical inputs into the management information system to improve internal controls, improve compliance with federal and state financial aid programs and to establish standard operating procedures for the University. The University has also purchased key reporting software and has a team in place that is designing detailed reports to help the University reach compliance and improve accuracy. The graduation data is sent to the National Student Clearinghouse on the last day of each term so that it falls within the 60-day reporting requirements.

FINDING 2021-005: SIGNIFICANT DEFICIENCY ? REPORTING Program: COVID-19 ? Education Stabilization Fund CFDA Number: 84.425F Federal Agency: U.S. Department of Education Federal Award Identification Number: P425F202178 Federal Award Year: June 30, 2021 Criteria: Section 18004(e) of the Coronavirus Aid, Relief and Economic Security Act (CARES Act), directed institutions receiving funds under Section 18004 of the Act, to submit a new, separate form covering aggregate amounts spent for HEERF I, HEERF II and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2) and (a)(3) funds and checks the ?final report? box. Condition: The University posted inaccurate reports to their website as the information included amounts reported in the wrong column and did not include cumulative amounts in the top section. Following the identification of the finding, the University submitted updated reports to reflect accurate presentation of the information noted previously. Questioned Costs: Not applicable. Context: Not applicable. Effect: The University did not provide the public with accurate and reliable data related to the HEERF Institutional Aid Portion. Cause: The University did not fill out the forms correctly nor in accordance with HEERF reporting requirements. Recommendation: The University should assign an individual to monitor reporting requirements of awards to ensure the University is in compliance. Management?s Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University?s initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.

FINDING 2020-003: SIGNIFICANT DEFICIENCY ? REVIEW OF AWARD PACKAGES Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2020 Repeat of Prior Year Finding 2019-003 Criteria: Department of Education regulations require recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In order to ensure the accuracy of award packages and the eligibility of the students receiving them, a proper system of review should be in place where there is a level of review that occurs, after the initial award package is created, that is performed by someone who is not the original preparer of the award package. Condition: Award packages that are created for students are not reviewed by anyone other than the original preparer prior to the funds being disbursed to students. Questioned Costs: None noted. Context: None of the award packages contained within student files, selected for testing, provided indication of a review that was performed by someone other than the original preparer. However, no Title IV over awards were noted during the testing of the student financial award packages during the current year audit. The sample was not considered statistically valid. Effect: Award packages could contain errors, students could be over awarded federal funds, or federal funds could be awarded to ineligible students. Cause: The Financial Aid Department has experienced a decrease in staffing levels in recent years. Resources are currently not available to allow for someone to review the award packages prior to awards being disbursed to students. Recommendation: We recommend that a policy is put in place where a level of review is performed after the initial award packages are created by someone who is not the original preparer. In addition, there should be written documentation (signature or initial on the award package by the reviewer) that verifies that the review was performed. Management?s Response: The Financial Aid module of the University?s student information system, Colleague, has been set up using rules so that students are not selected for auto-packaging until their file is complete. They are then run through an automated packaging process which uses rules to ensure federal aid is accurately awarded based on the student?s eligibility and within fund-level budget limits. The Financial Aid Systems Manager reviews the students who pass the rules to be packaged and then reviews the awards after the auto-packaging process is run.

FINDING 2020-004: VERIFICATION OF FAFSA INFORMATION Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2020 Criteria: 34 CFR 668.60(b)(1) states that if an applicant fails to provide the requested verification documentation that the institution may not disburse any additional FSEOG Program funds to the applicant, employ, continue to employ or allow an employer to employ the applicant under FWS, or originate the applicant's Direct Subsidized Loan or disburse any additional Direct Subsidized Loan proceeds for the applicant. Condition: For two students tested, University personnel were unable to provide documentation that verification procedures, including the verification of the income reported on the Free Application for Federal Student Aid (FAFSA), were completed. Questioned Costs: Not applicable. Context: The issue was noted with 2 out of the 25 students tested for verification testing who were selected for verification by the Department of Education during the 2019-2020 award year. The sample was not considered statistically valid. Effect: The University does not have documentation to support that the verification process was completed. Cause: The University does not have a system of proper controls and procedures in place to ensure that supporting documentation surrounding the verification process is retained. Recommendation: We recommend that a system of controls be put into place to ensure that all aspects of the verification process are completed prior to disbursing federal funds to students and that the supporting documentation of the completed verifications is retained. Management?s Response: In July 2020, the Financial Aid Office implemented the communications management module to track requests for information along with the receipt of student-submitted documentation. Once a file is ready to be reviewed, the verification processor uses a Financial Aid Verification Review Checklist that includes the information reported on the ISIR and includes the information from the verification documents submitted by the student. The reviewer makes all updates in the Colleague system, and then uses the Colleague system to export any ISIR corrections. Comments regarding the verification reviews are also documented in the system. All verification documentation is now scanned and entered into a secure network drive within the student?s electronic file.

FINDING 2020-005: SIGNIFICANT DEFICIENCY ? SCHOOL ACCOUNT STATEMENT (SAS) RECONCILIATIONS Program: Federal Direct Student Loans CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K201428 Federal Award Year: June 30, 2020 Repeat of Prior Year Finding 2019-005 Criteria: 34 CFR 685.300(b)(5) states that the University must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Recipients of federal awards are required to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition: Monthly reconciliations were performed sporadically during the year. In addition, none of the reconciliations that were completed were reviewed or apporved by anyone other than the original preparer. Questioned Costs: Not applicable. Context: Of the reconciliations that were completed, none of them were reviewed or approved by anyone other than the original preparer. Reconciliations were performed sporadically throughout the year. Effect: Reconciliations could contain errors or may not balance, resulting in variances between the University's records and the Department of Education records. Cause: Policies and procedures currently in place at the University do not require the review or approval of the SAS reconciliations. Recommendation: After the SAS reconciliations are completed, they should be reviewed and approved by someone other than the original preparer who would be knowledgeable enough to identify an error in the reconciliation. Management?s Response: In August 2020, the Financial Aid Office began a more concerted effort to reconcile the Pell, TEACH, and Direct Loan programs more often. Reconciliation is now completed after every transmittal run and at least once per month. A uniform spreadsheet was developed for each program to track and document the reconciliation process between Colleague and the COD system. The spreadsheet is shared with the Vice President for Enrollment Management and the University Controller.

FINDING 2020-006: SIGNIFICANT DEFICIENCY ? RETURN OF TITLE IV FUNDS CALCULATIONS Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2020 Repeat of Prior Year Finding 2019-006 Criteria: 34 CFR 668.22 requires that 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 in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: For one student selected for testing, the amount of the title IV refund was calculated incorrectly and the refund was not returned within 45 days. Questioned Costs: The amount refunded for one of the students selected for testing was $3,624 and the amount that should have been remitted to the government was $3,594. The amount refunded more than 45 days after the students withdrew was $3,624. Context: Errors were noted in the calculations for one of the five students selected for testing. In addition, refunds for one of the students was not returned within 45 days. There were a total of 26 students who withdrew during fiscal year 2020 that received Title IV aid. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. The University also failed to make a refund within the required timeframe. Cause: Total number of days used for the calculation did not incorporate breaks of five days or more. As such, the total amount calculated to be refunded was incorrect. Furthermore, the refund was returned more than 45 days after the students withdrew. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. Management?s Response: The setup of the R2T4 module was completed in the Colleague system. The Vice President for Enrollment Management and the Financial Aid Systems Manager review the academic calendar during setup to ensure that any school breaks are accurately reported in the system. Reports are run on a regular basis to capture any students who have withdrawn from the University. At the end of the term, a report is generated of students who failed all of their classes. The reports are reviewed within the required time period. This functionality is currently working accurately.

FINDING 2020-007: MATERIAL WEAKNESS ? FEDERAL DIRECT STUDENT LOAN ENROLLMENT REPORTING Program: Federal Direct Student Loans CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K201428 Federal Award Year: June 30, 2020 Repeat of Prior Year Finding 2019-007 Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a halftime basis for the period for which the loan was intended. Condition: For 30 students tested, the incorrect enrollment status was reported to NSLDS. In addition, for 7 students, the change of enrollment status was not reported within the 60 day requirement. Questioned Costs: Not applicable. Context: Noncompliance with federal regulations was noted for 36 of the 40 students who were tested. 7 of the students did not have their change in enrollment status reported to NSLDS within 60 days and 30 students did not show the correct change of status, and thus also did not have their change in enrollment status reported timely to NSLDS. A total of 268 students who were issued Federal Direct Student Loans separated from the University during fiscal year 2020. The sample was not considered statistically valid. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, updated, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause: It does not appear that there are proper processes in place surrounding enrollment reporting in order to verify that the correct dates are reported to NSLDS within the required timeframes. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Management?s Response: In August 2020, the Registrar informed the Vice President for Enrollment Management that the NSLDS reporting process was made more accurate and efficient. The graduation data is sent to the Clearinghouse on the last day of each term so that it falls within the 60-day reporting requirements.

FINDING 2020-008: SIGNIFICANT DEFICIENCY ? GRAMM-LEACH BLILEY ACT Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2020 Criteria: In accordance with Title IV regulations (16 CFR 314.1 (b)), an Institution must protect student financial aid information by designating an individual to coordinate the information security program, perform a risk assessment that addresses (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures, and document safeguards for identified risks. Condition: The University does not have documentation to support risk assessments performed to address employee training and management related to information security as required by the Gramm-Leach Bliley Act (GLBA). Questioned Costs: Not applicable. Context: Not applicable. Effect: Failure to comply with the requirements of GLBA standards puts the University at risk of compromising consumer, nonpublic personal information. Cause: The University does not have procedures and processes in place related to the GLBA. Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks related to protecting consumer nonpublic personal information. At a minimum, the University should have at least one risk statement aligned or referenced to each of the three required areas noted in the GLBA law at 16 CFR 314.4 (b). Finally, the University should identify and document at least one safeguard (i.e., control) for each of the risks identified and documented in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Management?s Response: In fall 2020, the Information Technology and Human Resources teams worked together to set up training in our Safe College Training portal. All employee and student training can be done through this portal. The portal is set up to verify who has taken training and a follow up plan on those who have not is being put into place.

FINDING 2019-003: SIGNIFICANT DEFICIENCY ? REVIEW OF AWARD PACKAGES Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2019 Repeat of Prior Year Finding 2018-003 Criteria: Department of Education regulations require recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In order to ensure the accuracy of award packages and the eligibility of the students receiving them, a proper system of review should be in place where there is a level of review that occurs, after the initial award package is created, that is performed by someone who is not the original preparer of the award package. Condition: Award packages that are created for students are not reviewed by anyone other than the original preparer prior to the funds being disbursed to students. Questioned Costs: None noted. Context: None of the award packages contained within student files, selected for testing, provided indication of a review that was performed by someone other than the original preparer. However, no need-based Title IV over awards were noted during the testing of the student financial award packages during the current year audit. See finding 2019-004 for a finding related to an over award of a non-need based award. The sample was not considered statistically valid. Effect: Award packages could contain errors, students could be over awarded federal funds, or federal funds could be awarded to ineligible students. Cause: The Financial Aid Department has experienced a decrease in staffing levels in recent years. Resources are currently not available to allow for someone to review the award packages prior to awards being disbursed to students. Recommendation: We recommend that a policy is put in place where a level of review is performed after the initial award packages are created by someone who is not the original preparer. In addition, there should be written documentation (signature or initial on the award package by the reviewer) that verifies that the review was performed. Management?s Response: With the addition of the Student Financial Services Manager in November 2019, there is now adequate staff for one staff to create the initial award package and another staff member to review and sign off on the award package. During the spring of FY 2020, we will create a process where one staff member will run the automated packaging setup and the Financial Aid Director will review the packages. This will be effective for the FY 2021 academic year.

FINDING 2019-004: OVERAWARD OF TITLE IV FUNDS Program: Federal Direct Loan Program CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K191428 Federal Award Year: June 30, 2019 Criteria: 34 CFR 685.203(c)(2) states that in order for a dependent undergraduate student to receive an additional unsubsidized loan amount, the financial aid administrator must determine that the student?s parent likely will be precluded by exceptional circumstances from borrowing under the Direct PLUS Loan Program and the student?s family is otherwise unable to provide the student?s expected family contribution. Condition: For one student tested, the student was a dependent undergraduate that received more unsubsidized loans than they were eligible to receive. There was no indication that the student?s parents were unable to borrow Direct PLUS Loans due to adverse credit or other exceptional circumstances that would make them eligible to receive addition Direct Unsubsidized Loan funds up to the same amount that is available to independent undergraduate students. Questioned Costs: The gross amount of the overaward for this student was $2,000. Context: The issue was noted with one out of the 23 dependent undergraduate students tested for general complianCe that received student financial aid during the 2018-2019 award year. The sample was not considered statistically valid. Effect: Students at the University could be receiving more unsubsidized loans than they are eligible. Cause: Proper controls are not in place (see finding 2019-003) to verify that a dependent student was indeed eligible for additional Direct Unsubsidized Loan funds. Recommendation: We recommend that a system of controls be put into place to ensure that all dependent undergraduate students who receive additional unsubsidized funds have the appropriate support for these additional funds. This should include a review performed by someone independent of the individual putting together the award package. Management?s Response: Starting in January 2020, we began reviewing the annual setup process and the parameters in our software to achieve automation. During this review, we have identified that the eligibility rules are not set up properly. With this correction, eligibility rules will mitigate the occurrence of overawarding.

FINDING 2019-005: SIGNIFICANT DEFICIENCY ? SCHOOL ACCOUNT STATEMENT (SAS) RECONCILIATIONS Program: Federal Direct Student Loans CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K191428 Federal Award Year: June 30, 2019 Repeat of Prior Year Finding 2018-005 Criteria: 34 CFR 685.300(b)(5) states that the University must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Recipients of federal awards are required to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition: Of the reconciliations that were completed, none of them were reviewed or approved by anyone other than the original preparer. Furthermore, reconciliations were not performed monthly until November 2018. Questioned Costs: Not applicable. Context: Of the four monthly reconciliations selected for testing, none were reviewed or approved by anyone other than the original preparer. The sample was not considered statistically valid. Effect: Reconciliations could contain errors or may not balance, resulting in variances between the University's records and the Department of Education records. Cause: Policies and procedures currently in place at the University do not require the review or approval of the SAS reconciliations. Recommendation: After the SAS reconciliations are completed, they should be reviewed and approved by someone other than the original preparer who would be knowledgeable enough to identify an error in the reconciliation. Management?s Response: In our process improvement work sessions, we have identified issues with the reconciliation process. Now that the past years? reconciliations are completed, the reconciliations are to be completed on a monthly basis starting in February 2020. With the additional hire of a Student Financial Services Manager, we can have a review process in place. Additionally, we have agreed that no entries will be made directly into COD, which was the core reason of errors in reconciliations from past years. If there is an issue reconciling, Financial Aid is to contact IT for a best practice of the software Datatel and, if there is no resolution, IT will put in a tech ticket with Datatel to resolve. When reviewing the daily COD reject report, we will identify issues that need to be resolved prior to the monthly reconciliation. The Financial Aid Director will complete the reconciliation and the Student Financial Services Manager will review the reconciliation.

FINDING 2019-006: SIGNIFICANT DEFICIENCY ? RETURN OF TITLE IV FUNDS CALCULATIONS Program: Student Financial Assistance Cluster CFDA Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2019 Repeat of Prior Year Finding 2018-010 Criteria: 34 CFR 668.22 requires that 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 in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: For one student selected for testing, the amount of the Title IV refund was calculated incorrectly, and for three of the students selected, the refund was not returned within 45 days. Questioned Costs: The amount refunded for one of the students selected for testing was $2,474, and the amount that should have been remitted to the government was $2,410. The amount refunded more than 45 days after the students withdrew was $15,884. Context: Errors were noted in the calculations for one of the four students in which refund calculations were performed. In addition, refunds for three of the four students were not returned within 45 days. There were a total of 42 students who withdrew during fiscal year 2019. The sample was not considered statistically valid. Effect: The amounts refunded to the Department of Education may be incorrect. The University also failed to make three refunds within the required timeframe. Cause: Total number of days used for the calculation did not incorporate breaks of five days or more. As such, the total amount calculated to be refunded was incorrect. Furthermore, three refunds were inadvertently returned more than 45 days after the students withdrew. Recommendation: We recommend that University personnel review the calculations generated by the University's software system. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify accuracy of the calculations. Furthermore, the University should remit refunds within the 45 day required timeframe. Management?s Response: We are researching how the system, Datatel, can further the use of efficiencies in relation to the R2T4 process. In discussions with IT, it has been identified that the system is not being used correctly for withdraws and that may be affecting the timing of returning funds. An enhancement to the Registration Withdrawal Form was made to help identify students that need to receive an exit interview form and to help meet the 45-day deadline. Financial Aid Services (FAS) is processing our R2T4 calculations, refunds and exit counseling for 2019/2020. The listing of withdrawals for 2019/2020 has been sent to them, and we are updating the Spring listing as we receive withdrawal paperwork.

FINDING 2019-007: MATERIAL WEAKNESS ? FEDERAL DIRECT STUDENT LOAN ENROLLMENT REPORTING Program: Federal Direct Student Loans CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K191428 Federal Award Year: June 30, 2019 Repeat of Prior Year Finding 2018-011 Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: For 34 students tested, the student?s change of enrollment status was not reported within the 60 day requirement. Of these 34 students, 17 had been reported with an incorrect enrollment status. Questioned Costs: Not applicable. Context: Noncompliance with Federal regulations were noted for 34 of the 40 students who were tested. Of these 34 students, 17 had been reported with an incorrect enrollment status. A total of 324 students who were issued Federal Direct Student Loans separated from the University during fiscal year 2019. The sample was not considered statistically valid. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be in accurate impacting student loan repayments. Cause: It does not appear that there are proper processes in place surrounding enrollment reporting in order to verify that the correct dates are reported to NSLDS within the required timeframes. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates are reported to NSLDS within required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Management?s Response: The Registrar enters student withdrawal and graduation information into Datatel. Since we are processing SSCR enrollment status files monthly directly from Datatel, we intend to eliminate any late or incorrect reporting. The Registrar, Financial Aid Department, and the IT Department will begin in March 2020 the review of internal procedures for process improvements. A ticket was submitted in February 2020 to the Clearinghouse to identify possible software issues.

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