Southern Oregon UniversityHigher Education

Special Tests – Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Number: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program Federal Award Identification: Various Award Period: June 1, 2024 to June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. The University must also have an adequate process to internally review submissions to either the third-party servicer or directly to NSLDS. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance. 1. 1 student enrollment changes where the enrollment status effective date was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) 2. 5 instances where a student’s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) 3. 1 student enrollment change where status change was not reported to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) Questioned costs: N/A Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 6 students with exceptions. 1 student had multiple instances of noncompliance. Cause: The university was unaware of the errors which were caused by the transmission of date between their student information system and the third-party servicer. Effect: The NSLDS system could not be updated accurately or timely with student enrollment information. Repeat finding: Yes 2024-001 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.

Special Tests – Return to Title IV Funds (R2T4) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Numbers: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program 84.007 – Federal Supplemental Educational Opportunity Grants 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification: Various Award Period: June 1, 2024 to June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: 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 is required to determine the amount of Title IV aid earned as of the student’s withdrawal date. If the amount of Title IV aid earned is less than the amount disbursed to the student or on the student’s behalf as of the date the institution determines the student withdrew, the institution must return the unearned portion to the applicable Title IV programs. No additional disbursements may be made for the payment period or period of enrollment. If the amount of Title IV aid earned exceeds the amount disbursed, the difference must be treated as a post-withdrawal disbursement, in accordance with 34 CFR §668.22(a)(1) through (a)(5). Condition: During our testing of students who ceased attendance during a payment period or period of enrollment—including students who met withdrawal exemptions, dropped courses, took a leave of absence, never began attendance, or otherwise terminated enrollment during the audit period—we selected a sample of 15 students to evaluate the timeliness and accuracy of Return to Title IV (R2T4) calculations and procedures. We identified that the Student Financial Aid system did not calculate R2T4 amounts accurately for 5 of the 15 students tested. In addition, there was insufficient review of system-generated calculations to ensure their accuracy. For these students, the return of funds was not completed within the required 45-day timeframe from the date the institution determined the student withdrew. Questioned costs: $6,644 Context: The University did not properly review system generated calculations. 5 out of the 15 students tested had incorrect calculations and the dates funds were returned not completed withing 45 days of the institution determining the student's withdrawal. Cause: The deficiencies were primarily due to ineffective internal controls over the R2T4 process and errors in system-generated calculations. These issues were further exacerbated by staff turnover that occurred prior to the Fall 2024 term. Effect: As a result, Title IV funds may not have been returned in the correct amounts or within required timeframes, resulting in noncompliance with federal regulations governing the administration of Title IV financial aid programs. Repeat finding: No Recommendation: We recommend that the University strengthen internal controls over the R2T4 process by implementing standardized procedures, ensuring system calculations are accurate, and establishing consistent and documented review of R2T4 calculations prior to the return of Title IV funds. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.

Eligibility – Direct Loan Awarding Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Numbers: 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: P268K240362 2025 Award Period: June 1, 2024 to June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirements: Direct Subsidized Loans and Direct Unsubsidized Loans are subject to annual loan limits that vary based on a student’s grade level and, for Direct Unsubsidized Loans, dependency status, in accordance with 34 CFR §685.203. The annual loan limit represents the maximum amount a student may receive for an academic year. For undergraduate students, there is a combined annual loan limit for Direct Subsidized and Direct Unsubsidized Loans, of which no more than a specified portion may consist of Direct Subsidized Loans (the “annual subsidized maximum”). Condition: During eligibility testing, we identified one student who was classified as an independent junior and was eligible to receive up to $5,500 in Direct Subsidized Loans. However, the student was awarded only $5,000 in Direct Subsidized Loans. The student was also awarded $7,500 in Direct Unsubsidized Loans, consistent with the applicable annual loan limit. The student’s financial aid package was adjusted using professional judgment; however, an error in recalculation resulted in the student being underawarded $500 in Direct Subsidized Loans and overawarded Direct Unsubsidized Loans by $500. Questioned costs: None. Context: Out of a sample of 41 students tested for eligibility of federal student financial aid awards, the University did not properly award one student the full amount of Direct Subsidized Loan for which the student was eligible. Cause: The error was due to human error during the manual packaging and recalculation process. Effect: The student was underawarded Direct Subsidized Loans and correspondingly overawarded Direct Unsubsidized Loans during the 2024–2025 award year. Repeat finding: No Recommendation: We recommend that the University enhance its policies and procedures related to the packaging and awarding of financial aid, particularly in situations requiring manual calculations or professional judgment, to ensure student eligibility is accurately determined and awards are properly calculated. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.

Special Tests – Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Number: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program Federal Award Identification Number and Year: P063P230362 2024 and P268K240362 2024 Award Period: June 1, 2023 to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. The University must also have an adequate process to internally review submissions to either the third-party servicer or directly to NSLDS. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance. 1. 10 individual students where a student's campus-level enrollment effective date was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) 2. 13 instances where a student’s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) Questioned costs: N/A Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 21 students with exceptions. 2 students had multiple instances of noncompliance. Cause: Turnover at the university did not lead to adequate corrective action taken after the prior year audit. The University was unaware of the errors which were caused by the transmission of data between there student information system and the third-party servicer. Effect: The NSLDS system could not be updated accurately or timely with student enrollment information. Repeat finding: Yes 2023-001 Recommendation: We recommend that the University ensure it has enhanced its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. View of responsible official: The University agrees with the finding.

Eligibility – Direct Loan Entrance Counseling Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Numbers: 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: P268K240362 2024 Award Period: June 1, 2023 to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: As outlined under 34 CFR 668.164(l), an institution is required to ensure entrance counseling has been performed before disbursing Direct loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan and Direct PLUS Loan to a graduate or professional student. Condition: During our testing, one of the 40 students selected for testing did not receive entrance counseling prior to receiving their first Grad PLUS Direct Loan Disbursement. Questioned costs: Federal Direct Student Loans - $3,381. Context: Out of our population and sample of 40 students, the University did not document 1 student’s entrance counseling completion. Cause: The University’s processes and controls did not ensure that entrance counseling was completed or did not retain proper support to indicate this process took place. Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate. Repeat finding: No Recommendation: We recommend the Institute review its policies and procedures around sending entrance information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made. View of responsible official: The University agrees with the finding.

Special Tests – Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Numbers: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program Federal Award Identification Number and Year: P063P230362 2024 and P268K240362 2024 Award Period: June 1, 2023 to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: An institution must provide to Department of Education an up-to date URL for the contract for publication in a centralized database accessible to the public. Unless the school has a Tier Two arrangement under the threshold, the URL must also include the contract data described in the paragraph above (34 CFR 668.164(e)(2)(viii); 668.164(f)(4)(iii)(B); 668.164(f)(4)(v)). Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing the University could not provide support that an up-to-date contract establishing their tier two arrangement was provided to the Department of Education. Questioned costs: N/A Context: The University did not meet the compliance requirement to report the contract and contract components to the Department of Education. Cause: Turnover at the university did not lead to adequate corrective action taken after the prior year audit. The University was not aware of the requirement and previously personal did not retain applicable support, if completed. Effect: The Department of Education was not provided required information regarding the contract. Repeat finding: Yes 2023-003 Recommendation: We recommend that the University ensure it has enhanced its policies and procedures to ensure required contracts and contract components are provided to the Department of education when required. View of responsible official: The University agrees with the finding.

Special Tests – Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Number: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program Federal Award Identification Number and Year: P063P220362, 2023 AND P268K230362, 2023 Award Period: June 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. The University must also have an adequate process to internally review submissions to either the third-party servicer or directly to NSLDS. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance. 1. 1 individual student where a student's campus-level enrollment status was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) 2. 7 individual students where a student's campus-level enrollment effective date was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) 3. 34 instances where a student’s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) 4. 1 instance where a student’s program-level enrollment effective date did not match the institutions records. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) Questioned costs: N/A Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 40 students with exceptions as described above. 5 students had multiple instances of noncompliance. Cause: The University was unaware of the errors which were caused by the transmission of data between there student information system and the third-party servicer. Effect: The NSLDS system could not be updated accurately or timely with student enrollment information. Repeat finding: No Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. View of responsible official: The University agrees with the finding.

Special Tests – 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Numbers: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program. Federal Award Identification Number and Year: P063P220362, 2023 AND P268K230362, 2023 Award Period: June 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: As outlined under 34 CFR 668.164(l), an institution must have a process that ensures SFA funds are never escheated to a state, revert to the institution, or revert to any other third party. Additionally, if a check sent to a student or parent is not returned to the institution and is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing of outstanding SFA checks, we identified nine checks outstanding that had not been returned to the Department of Education within 240 days. Questioned costs: Federal Pell Grant - $2,691; Federal Direct Student Loans - $3. Context: Out of our population and sample of nine outstanding SFA checks, we noted all nine had the exception described above. Cause: The University had been under the impression that Pell checks may go stale dated and escheat to the state as unclaimed until an internal auditor informed the School that all Title IV aid is to be returned to the DOE and not allowed to escheat, including the Federal Pell Grant. After the internal audit, it was identified that two of the checks were Direct Loans and not Pell. Effect: The University did not return all SFA funds timely. Repeat finding: No Recommendation: We recommend that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue. View of responsible official: The University agrees with the finding.

Special Tests – Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Numbers: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program Federal Award Identification Number and Year: P063P220362, 2023 AND P268K230362, 2023 Award Period: June 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: An institution must provide to Department of Education an up-todate URL for the contract for publication in a centralized database accessible to the public. Unless the school has a Tier Two arrangement under the threshold, the URL must also include the contract data described in the paragraph above (34 CFR 668.164(e)(2)(viii); 668.164(f)(4)(iii)(B); 668.164(f)(4)(v)). Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing the University could not provide support that an up-to-date contract establishing their tier two arrangement was provided to the Department of Education. Questioned costs: N/A Context: The University did not meet the compliance requirement to report the contract and contract components to the Department of Education. Cause: The University was not aware of the requirement and previously personal did not retain applicable support, if completed. Effect: The Department of Education was not provided required information regarding the contract. Repeat finding: No Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the Department of education when required. View of responsible official: The University agrees with the finding.

Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. In accordance with section 2003 of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education and section 2003 of the ARP and section 314 of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) (Pub. L. 116-260), recipients must promptly and timely provide a detailed accounting of the use and expenditure of the funds provided by these supplemental award in such manner and with such frequency as the Secretary may require. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: The University is not in compliance with quarterly and annual reporting requirements for HEERF Institutional and Student Grants. Questioned costs: N/A Context: We tested two of the four required quarterly student reports, two of the four required quarterly institutional reports, and the one required annual report. During our testing of this sample for the HEERF reporting requirements at Southern Oregon University, we noted: 1) Non-Compliant Student Quarterly Reporting a. Neither of the two quarterly student reports tested had an acknowledgement that the University signed and returned to the Department of Education the Certification and Agreement and the assurance that the University has used the applicable amount of funds designated under the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) to provide Emergency Financial Aid Grants to Students. Both of these were required elements of the student quarterly reporting. b. On both reports tested, the University reported total amount of emergency financial aid grants distributed, the estimated total number of students at the institution that are eligible to receive emergency financial aid grants, and the total number of students who have received an emergency financial aid grant cumulatively, not on a quarterly basis. Additionally, the reports were cumulative as of days mid-month. 2) Non-Compliant Institutional Quarterly Reporting. a. The Original report published for the third quarter of 2021 was not retained on the website. The revised report was published in January 2022. Ultimately the reports were not posted timely within the 10-day requirement. b. The first quarter of 2022 report was also published 1 day after the deadline on 4/11/2022. 3) Non-Compliant Annual Reporting a. Institutional amounts spent in accordance with section 2003(5) of the American Rescue Plan Act of 2021 were not correctly reported on the 2021 annual report. Specifically, no amounts were reported for earmarking requirements in accordance with the ARP Institutional Appropriation expended in 2021. Cause: Staff turnover and misunderstanding of reporting guidance caused the reporting non-compliance. Effect: The University was not in compliance with HEERF reporting requirements. Repeat finding: Yes 2021-003 Recommendation: We recommend that the University continue to review their reporting policies and procedures to ensure accurate and timely reporting. View of responsible official: The University agrees with the finding.

Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance. 1. 20 individual students? enrollments were not certified at least once every 60 days. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2). 2. Eight instances where a student?s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(2) and 34 CFR 690.83(b)(2). Questioned costs: N/A Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 27 exceptions as described above. Cause: The University was unaware of the errors which were caused by the transmission of date between there student information system and the third-party servicer. Effect: The NSLDS system could not be updated accurately or timely with student enrollment information. Repeat finding: Yes, 2020-005 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. View of responsible official: The University agrees with the finding.

Criteria or specific requirement: 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)). Condition: We sampled 40 students that were withdrawn, dropped, on a leave of absence, never began attendance or terminated during the audit period to ascertain if returns of Title IV funds were properly calculated and timely processed. Our testing identified 13 instances where the return of Title IV calculation was incorrectly calculated. Eight of the 13 instances were disbursed funding subsequent to their withdrawal causing an inadvertent overpayment. The institution incorrectly included aid as disbursed in the R2T4 calculation instead of including the Aid in the "could have been disbursed" column. (DCL GEN-04-03 Revised, November 2004). The remaining five instances of noncompliance were due to either using the wrong last day of attendances and/or an incorrect amount of aid disbursed or could have been disbursed within the calculation. Questioned costs: $14,563 Context: Out of a sample of 40 students tested we noted 13 students whose return to Title IV calculation was incorrect. Cause: The University changed its policy and procedures in the Fall 2020 term, as a result of the pandemic, to disburse aid to students earlier, which lead to the inadvertent overpayment noncompliance noted. The University?s policy to determine last day of attendance or academic activity changed as a result of the pandemic which led to incorrect calculations performed. Effect: The University is not returning the proper amounts to the Department based on the calculations performed. Repeat finding: No Recommendation: We recommend the University review student withdrawal policies and procedures to ensure all changes adopted as a result of normal operation and pandemic operations will allow the institution to actually and timely process funds that may need to be returned as a result of any returns to Title IV calculations. View of responsible official: The University agrees with the finding.

Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: The University is not in compliance with reporting requirements for HEERF Grants. Questioned costs: N/A Context: We tested two of the four required quarterly student reports, two of the four required quarterly institutional reports, and the one required annual report. During our testing of this sample for the HEERF reporting requirements at Southern Oregon University, we noted: 1) Non-Compliant Student and Institutional Quarterly Reporting ? Both quarterly student reports selected for testing were not posted on the University?s website. (9/30/2020 and 12/31/2020) One of the two institutional reports selected for testing was reported cumulatively, rather than quarterly. (12/31/2020) 2) Non-Compliant Annual Reporting ? The University did not report any HEERF Emergency Financial Aid Grant Eligible Students and count of HEERF Emergency Financial Aid Grants Disbursed to Students in the annual report did not agree to supporting documentation. Cause: Staff turnover and misunderstanding of reporting guidance caused the reporting non-compliance. Effect: The University was not in compliance with HEERF reporting timing requirements. In addition, some of the data reported could not be supported. Repeat finding: No Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. View of responsible official: The University agrees with the finding.

Criteria or specific requirement: Federal regulations require institutions to package students with Title IV funding based on other estimated financial assistance, their expected family contribution (EFC), student status, and other financial metrics to ensure a student is not awarded more need-based aid than their financial need and not awarded more than their Cost of Attendance (COA) with both need and non-need based aid. Any changes in funding that affect the amount of aid a student could be awarded must be considered and, if applicable, Title IV funding must be adjusted to ensure students are appropriately packaged. If revisions are not considered, a student could be underpackaged or overpackaged. Condition: During our eligibility testing, there were five students that were either over awarded or under awarded Federal Direct Subsidized Loans and/or Federal Direct Unsubsidized Loans during a semester. Three Students were under awarded Federal Direct Unsubsidized Loans and two students were under awarded Federal Direct Subsidized Loans but over awarded Federal Direct Unsubsidized Loans. The net impact of these five students was the school under awarded Federal Direct Loans in the amount of $3,576 for the period under audit. Questioned costs: None Context: In our sample of 40 students who were awarded federal aid, CLA noted that five students were under awarded direct loans. CLA noted that these students had changing factors (such as changes to COA, EFC, and other aid awarded) after the initial award processing and were not subsequently repackaged or correctly updated. Cause: The Institution did not have formal procedures in place to review and adjust aid awards as changes to COA, EFCs, or other aid awards occurred. Effect: Students could be over awarded or under awarded financial aid due to changed or adjustments after initial packaging. Repeat finding: No Recommendation: CLA recommends that the University enhance its policies and procedures for when students? financial aid package inputs (COA, EFC, other aid, etc.) change after the initial award processing. View of responsible official: The University agrees with the finding.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.304 requires entrance counseling be performed before disbursing loan funds to students for Direct Subsidized Loans, Direct Unsubsidized Loans and Direct PLUS Loans. The regulations also require exit counseling for all students who cease at least half-time study at the school. Condition: The University utilizes Exit Letters as part of satisfying the exit counseling requirement. During our testing, we noted one instance in which an Exit Letter was not sent to a student that graduated. Questioned costs: N/A Context: In our sample of 40 students who were awarded federal aid, CLA noted one graduate student who was not provided an Exit Letter. The student did appear on the exit counseling report for the Financial Aid Counselors to send the letter; yet, the counselors failed to send the letter to the student. Cause: The Institution has a manual process to send Exit Letters to students upon graduation. This manual process led to the error of the student not being sent the Exit Letter. Effect: Students are not all receiving the proper loan counseling which may contribute to a higher default rate. Repeat finding: No Recommendation: CLA recommends that the University review its policies and procedures for when a student withdrawals or graduates from the University to ensure exit counseling for applicable students is provided. In reviewing its policies and procedures, the University may want to consider a more automated process to reduce the risk of error. View of responsible official: The University agrees with the finding.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, ?Whenever an institution disburses title IV, HEA program funds by crediting a student?s account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but? (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.? Condition: During our testing, CLA noted one instance in which a student?s credit balance was not paid to the student within 14 days. Questioned costs: N/A Context: In our sample of 40 students who were awarded federal aid, we noted one instance in which a tuition charge reversed created a credit balance on a student?s account that would have been caused by federal funds; however, the refund wasn?t paid to the student within 14 days. Cause: The Institution?s policy regarding credit balances did not encompass mid-semester tuition and fee adjustments which could cause a credit balance. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations noted above. Repeat finding: No Recommendation: CLA recommends that the University review its policies and procedures for ensuring student credit balances are addressed withing 14 days of occurring, regardless of how they develop or when they occur. View of responsible official: The University agrees with the finding.

Criteria or specific requirement: Title IV funds may be expended only towards the education of the students who can be proved to have attended the institution. In a distance education context, documenting that a student has logged into an online distance education platform or system is not sufficient, by itself, to demonstrate academic attendance by the student per 34 CFR 668.22(l)(7). Condition: During our testing to determine whether the Institution was in compliance with the distance education attendance requirements for students awarded Title IV funds, we noted two distance education students that academic attendance records could not be provided. Questioned costs: $8,735 Context: In our sample of 40 students who received Title IV aid while attending online courses during a payment period, we noted two students whom academic attendance could not be provided. Cause: The University had to transition to Distance Learning as a result of the pandemic in Spring 2020 and some academic attendance documentation was not retained for various students. Effect: Students who are not actually attending courses could be provided Title IV funding when they are not eligible. Repeat finding: No Recommendation: We encourage management to review policies and procedures for documenting attendance for students who are enrolled exclusively in online courses during the applicable payment period a student received Title IV Aid. View of responsible official: The University agrees with the finding.

Criteria or specific requirement: Institutions are required to report enrollment information under the Pell Grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 34 of 40 student enrollment changes tested had one or more instances of noncompliance noted below: I. 32 individual students where enrollments were not certified at least once every 60 days. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) II. 4 instances where the campus level enrollment effective date was not reported accurately. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) III. 13 instances where a student?s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(2) and 34 CFR 690.83(b)(2) IV. 1 instance where the campus and program enrollment effective dates was incorrectly reported. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) Questioned costs: N/A Context: Our sample included a statistically valid sample of 40 student enrollment changes selected for testing, which derived from 35 unique students. There were approximately 34 unique student enrollment changes that exhibited at least one item of noncompliance which derived from approximately 32 unique students. Cause: The School was unaware of the errors which were caused by the transmission of date between there student information system and the third-party servicer. Effect: The NSLDS system was not updated with correct student information which could cause over subsequent awarding issues or repayment term discrepancies. Repeat finding: No Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. View of responsible official: The University agrees with the finding.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 676.10(a)(1) and (2) states ?In selecting among eligible students for FSEOG awards in each award year, an institution shall select those student with the lowest expected family contributions (EFC) who will also receive Federal Pell Grants in that year. If the institution has FSEOG funds remaining after giving FSEOG awards to all the Federal Pell Grant recipients at the institution, the institution shall award the remaining FSEOG funds to those eligible students with the lowest EFC who will not receive Federal Pell Grants.? Condition: The University awarded FSEOG to a student with a non-zero EFC, while eligible students with a zero EFC did not receive an FSEOG award. The amount incorrectly awarded to this student was $333. Questioned costs: $333 Context: During our eligibility testing, we noted one student out of 40 students (13 of which received FESOG) tested in a statistically valid sample, who was awarded FSEOG funds with a non-zero EFC. Cause: Initially, the student?s ISIR reported a $0 EFC and she was properly awarded FSEOG funds. Five months later, upon verification, her EFC was increased to $1,336 (above $0) in which she became ineligible for aid. Yet, the University did not make the necessary adjustments to remove the FSEOG award despite having reports showing the EFC did increase above $0. Effect: FSEOG was given to a student with an EFC other than zero, when eligible students with zero EFCs did not receive FSEOG. Repeat Finding: No Recommendation: We recommend the University evaluate the procedures over the awarding FSEOG funds, specifically when the EFC increases, to ensure that students with greatest financial need receive FSEOG before other eligible students. View of Responsible Official: The University agrees with the finding.

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