Doane University

Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable Assistance Listing Number - 84.268 Federal Award Number - P268K251776 Federal Award Year - June 30, 2025 Repeat Finding: 2024-001 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition/Context: During the year, there was no documented internal controls in place over the Title IV refund calculations. In the sample of 5 students that withdrew from the University, there was one student for which the return was calculated incorrectly. The result was too much aid being refunded. The sample was not a statistically valid sample. Questioned Costs: A total of $251 of subsidized direct loans for one student Cause: The University’s financial aid department has a limited number of individuals, and they experienced turnover during the year. Effect: The University returned incorrect amount to the US Department of Education. Recommendation: The University should document controls in place to ensure R2T4 calculations are complete and accurate. This should include a review of the calculations by someone other than the preparer prior to the refund being issued. Management Response: Due to staff turnover the change as noted in the FY2024 audit was not implemented. Management has now automated and implemented changes in systems controls for all Title IV refund calculations.

Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable Assistance Listing Number - 84.268 Federal Award Number - P268K251776 Federal Award Year - June 30, 2025 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) 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, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) 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 institution, 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; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: Of 25 students tested, the status date for one student selected was not reported timely on the campus level reporting in National Student Loan Data System (NSLDS). The sample was not a statistically valid sample. Cause: The University noted the reporting was completed timely to the servicer National Student Clearinghouse (NSC) however was not reflected in NSLDS. 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 inaccurate. Questions Costs: Not applicable Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management Response: Management has adjusted processes to ensure all student updates are correctly captured.

Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable Assistance Listing Number - 84.268 Federal Award Number - P268K251776 Federal Award Year - June 30, 2025 Criteria: Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). Additionally, when Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Condition/Context: Of the sample of 25 disbursements in the sample, seven students tested did not receive proper notification of the student's right, or parent's right to cancel any portion of the loans to be distributed. The sample was not a statistically valid sample. Cause: The University's controls surrounding notification of Title IV disbursements did not appropriately ensure the communications sent to students and parents contained all of the required information. Effect: Students were not properly notified of their student’s right, or their parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan payments returned to ED. Questions Costs: Not applicable Recommendation: The University should revise its procedures to ensure that notifications of Title IV fund disbursements contain all the information required by CFR 668.165. Management Response: Management has updated notification processes to ensure appropriate and timely notifications are sent to students.

Finding 2024-001: Significant Deficiency – Lack of Documented Controls - Refunds of Title IV Funds Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable Assistance Listing Number - 84.268 Federal Award Number - P268K241776 Federal Award Year - June 30, 2024   Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition/Context: During the year, there was no documented internal controls in place over the Title IV refund calculations. Despite the lack of documented controls over the R2T4 calculations, in a sample of 5 students that withdrew from the University, there were no compliance exceptions noted. The sample was not a statistically valid sample. Questioned Costs: Not applicable Cause: The University’s financial aid department has a limited number of individuals, and they experienced turnover during the year. Effect: Not applicable Questioned Costs: Not applicable Recommendation: The University should document controls in place to ensure R2T4 calculations are complete and accurate. This should include a review of the calculations by someone other than the preparer prior to the refund being issued. Management Response: Management will implement a system of controls for all Title IV refund calculations.

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/Context: In a sample of 7 students that withdrew during the fiscal year, the University calculated the required return to Title IV for one student incorrectly by using the incorrect number of days for the base. The sample was not a statistically valid sample. Cause: The University incorrectly used the wrong number of days as a base for the spring semester to use in the return of Title IV funds calculation. Effect: The return of Title IV (R2T4) funds calculations were incorrect for the Spring 2023 term requiring the student to return more than required. Questioned costs: The error resulted in $43 more in Direct Student Loan funds returned than required. Recommendation: It is recommended that the University review interpretations, policies and procedures in place for withdrawals and R2T4 calculations to ensure that correct dates and institutional charges are being used. Management Response: The Financial Aid office reviewed documentation to determine the total number of students impacted by this finding. No corrections to other students are required. This finding was reviewed and discussed with Financial Aid staff, including training, to review correct calculations for future semester/term calendar days. The University also reviewed days uses for 2023-2024 calendar to ensure they are in line with regulations.

Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) 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, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) 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 institution, 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; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: For one out of a sample of 25 students, the effective date reported to NSLDS for a withdrawn student was the date of determination rather than the last date of attendance. The sample was not a statistically valid sample. Cause: The University failed to follow its procedures for reporting student status changes correctly and/or within the required timeframe. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. 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 inaccurate. Questioned costs: Not applicable. Context: Not applicable. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct program level effective dates and enrollment statuses are reported to the NSLDS within the required timeframes after the information has been submitted through the servicer (National Student Clearinghouse). This could include a review of withdrawal or graduation dates compared to the effective dates and enrollment statuses reported to the NSLDS to make sure they are accurate. Management Response: For the one student found to have the incorrect date reported, the University is conducting additional training in the registrar’s office and will continue to focus on improving procedures to ensure the correct date is reported.

Finding 2022-002: Significant Deficiency - Enrollment Reporting Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable Assistance Listing Number - 84.268 Federal Award Number - P268K221776 Federal Award Year - June 30, 2022 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) 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, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) 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 institution, 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; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The change in status for two of twenty-five students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The change in status information for five of twenty-five students tested did not agree between the campus level and program level enrollment detail. The date for the change in status for eleven of twenty-five students tested did not agree to the University's records. The total number of students impacted is thirteen due to students being included in multiple categories noted above. The sample was not a statistically valid sample. Cause: The University failed to follow its procedures for reporting student status changes correctly and/or within the required timeframe. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. 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 inaccurate. Questioned costs: Not applicable. Context: Not applicable. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct program level effective dates and enrollment statuses are reported to the NSLDS within the required time frames after the information has been submitted through the servicer (National Student Clearinghouse). This could include a review of withdrawal or graduation dates compared to the effective dates and enrollment statuses reported to the NSLDS to make sure they are accurate. Management Response: Doane University continues to work to fine tune the internal process for reporting student enrollment status changes to NSLDS via the National Student Clearinghouse (NSC), including increased student communication regarding specific withdrawal dates.

Finding 2022-003: Significant Deficiency - Lack of Documented Review of Controls Federal Program - Student Financial Assistance Cluster Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable Assistance Listing Number - Various Federal Award Number - Various Federal Award Year - June 30, 2022 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 key student financial assistance processes, a proper system of review should be in place where the work of one is reviewed by someone who is not the original preparer. The review process should be documented. Condition: Various key student financial assistance processes, such as monthly Direct loan reconciliations and drawdowns of federal funds, have been performed, but there is no evidence of documented reviews. In addition, it was noted that the servicer's internal control report for the Perkins Loan Program was not reviewed. The sample was not a statistically valid sample. Cause: There was turnover during the year which resulted in a lack of documented reviews. Effect: Errors related to student financial assistance processes could occur and not be detected in a timely manner by employees in the normal course of performing their assigned functions. Questioned costs: Not applicable. Context: There was a lack of documentation of review for the samples selected for Direct loan reconciliations, drawdowns of federal funds, and R2T4 calculations. In addition, there was no documentation of the servicer's report for the Perkins Loan Program. Recommendation: We recommend that procedures and policies are put in place to ensure controls over student financial assistance processes are documented, including review by someone other than the preparer. Management Response: The Business Office at Doane University has implemented procedures to document the secondary review processes and review of servicer reports.

Finding 2022-004: Significant Deficiency - Late Filing of Single Audit Reporting Package Federal Program - All Federal Agency - All Pass-Through Entity - Not Applicable Assistance Listing Number - Various Federal Award Number - Various Federal Award Year - June 30, 2022 Criteria: Title 2 U.S. Code of Federal Regulations Part 200.512, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that the single audit reporting package be submitted the earlier of 30 days after receipt of the independent auditors' report, or 9 months after year end. Condition: The University's 2021 single audit reporting package was not submitted within the required timeframe. Cause: There was turnover during the year which contributed to the delay in filing the single audit reporting package. Effect: The single audit reporting package was submitted more than 30 days after receipt of the independent auditors' report, which was after the required reporting time period. Questioned costs: Not applicable. Context: Not applicable. Recommendation: The University should establish policies and procedures to submit the single audit reporting package within the required timeframe. Management Response: There was a miscommunication between the auditor at the time and the former Controller regarding the 30 day filing deadline for the single audit. Doane has implemented policies in coordination with the current auditor to ensure that future deadlines are met. Doane University also transitioned to a new audit firm for fiscal year ended June 30, 2022 to help ensure a smoother process.

Finding 2020-001 Federal Program Title ? Student Financial Assistance Cluster CFDA No. ? 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 Federal Agency ? U.S. Department of Education ? Direct Program Federal Award Numbers ? Not Applicable Grant Award Periods ? Not Applicable Compliance Requirement ? Special Tests and Provisions ? Enrollment Reporting Criteria: As set forth in 34 CFR Section 685.309(b)(2), participating schools in the Direct Loan Program are to notify the Secretary of Education if a Direct Loan had been made to or on behalf of a student who enrolled at the school but ceased to be enrolled on at least half-time basis or has or has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period which the loan was intended. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: The University did not have an effective system of internal control in place to ensure students enrollment status, for those who either withdrew or graduated from the University during the fiscal year, were properly reported to the National Student Loan Data System (NSLDS). While performing testwork over enrollment reporting, for 24 out of 60 students selected, the enrollment status was improperly reported to the NSLDS during fiscal year 2020. The students status change date was the last date of the defined reporting period rather than the end of the term enrollment period when the students status change took place. Questioned Cost: Questioned costs are not determinable. Context: For 24 out of 60 students selected for testwork, the University did not properly report to the NSLDS the enrollment status of the student during fiscal year 2020. Cause and Effect: University management indicated the University did not have an effective system of internal control in place, as prescribed by 2 CFR 200.303, to ensure that the data being input into the NSLDS system was accurate. As a result, 24 out of 60 students selected for testwork did not have accurate data reported to the NSLDS for enrollment status during fiscal year 2020.Repeat Finding: A similar finding was reported in prior year audit as finding number 2019-001. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University enhance its internal control process to ensure the University has effective internal controls in place to ensure that accurate enrollment status data is being submitted to the NSLDS as set forth in 34 CFR Section 685.309(b)(2). View of Responsible Official: We concur with the finding and are in process of updating the process to ensure accurate student withdrawal and graduation data is being submitted to the NSLDS. Contact Name: Ned Tucker, Interim CFO Contact Telephone Number: 402-826-8601

Findings and Questioned Cost Relating to Federal Awards. 2019-001. Program Information: Federal Agency: U.S. Department of Education. Federal Program Title: Student Financial Assistance Cluster (CFDA No. 84.007, 84.033, 84.038, 84.379, 84.268, and 84.063). Grant Identification Numbers: N/A. Compliance Requirement: Special Test--Enrollment Reporting. Criteria: 34 CFR Section 685.309(b)(2) requires participating schools in the Direct Loan Program to notify the Secretary of Education if a Direct Loan had been made to or on behalf of a student who enrolled at the school but ceased to be enrolled on at least half-time basis or has or has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period which the loan was intended. Condition Found: During our testwork, we selected 40 students who either withdrew or graduated from the University during the fiscal year. We identified 11 students out of whose enrollment status was improperly reported to the National Student Loan Data System (NSLDS). The students status change date was input as the date the data entry took place rather than the date the student's status change took place. Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None. Repeat Finding: No. Cause and Effect: Management failed to review the data being input into the NSLDS system for accuracy resulting in an inaccurate date being used as the student status change date. Recommendation: We recommend that the University update their process surrounding NSLDS data entry to accurately input the student withdrawal date into the NSLDS system. View of Responsible Officials: We concur with the finding and are in the process of updating the process surrounding NSLDS data entry to ensure accurate input of the student withdrawal date.

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