Eastern Oregon UniversityHigher Education

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification Number and Year: P268K252058-2025, P063P242058-2025, P007A253479-2025, P033A253479-2025, P379T262058-2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Compliance, Other Matter Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to ensure reasonable compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the effective date and enrollment status correctly or timely. In addition, the University did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned costs: None Reported. Context: During our testing, we noted that the enrollment effective date of 6 of the 60 students tested was not reported correctly to NSLDS. We also noted that the change in enrollment status of 3 of the 60 students tested was not reported timely to NSLDS. We also noted the program enrollment effective date of 2 of the 60 students tested did not match the enrollment effective date. Additionally, we did not note evidence of a key control occurring for enrollment reporting. Cause: The University did not have proper controls or procedures in place to verify students' status in NSLDS matched the institution’s records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2024-002. Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status, and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.063 Federal Award Identification Number and Year: P268K252058-2025, P063P242058-2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted that the University was unable to provide documentation evidencing the performance of a key control over the timeliness and accuracy of Common Origination and Disbursement (COD) disbursements reporting. Questioned costs: None reported. Context: The University could not provide evidence that the key control review was performed for any of the 60 disbursements selected for testing. Cause: The University does not maintain documentation to evidence their review to ensure disbursements are reported to COD timely and accurately. Effect: The absence of documented review increases the risk that disbursement data reported to COD may be inaccurate or untimely, which could result in inaccurate student records and may contribute to improper or excess student aid awards. Repeat Finding: Yes, 2024-004. Recommendation: We recommend the University retain evidence that key controls over COD reporting were performed. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification Number and Year: P268K252058-2025, P063P242058-2025, P007A253479-2025, P033A253479-2025, P379T262058-2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During eligibility testing, we noted that the University did not provide documentation evidencing that a review of a professional judgment decision had been performed. Questioned costs: None reported. Context: Of the 40 student files selected for eligibility testing, one student had a professional judgment determination. While supporting documentation for the professional judgement decision was available, the University was unable to provide evidence that the decision had been reviewed. Cause: The University does not maintain documentation to demonstrate that professional judgment decisions are subject to an independent review in accordance with established procedures. Effect: The lack of documentation of review of professional judgment decisions increases the risk that such determinations may not be appropriately evaluated, which could result in student financial need not being accurately assessed and students being improperly awarded or underserved. Repeat Finding: Yes, 2024-003. Recommendation: We recommend the University enhance its procedures for reviewing professional judgement decisions to ensure that evidence of review is documented and retained. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification Number and Year: P268K252058-2025, P063P242058-2025, P007A253479-2025, P033A253479-2025, P379T262058-2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Compliance, Other Matter Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) (Pub. L. No. 106-102) and its implementing regulations require financial institutions to protect the security, confidentiality, and integrity of customer information (16 CFR Part 314). Title IV-eligible institutions participating in the Federal Student Financial Assistance Programs are considered financial institutions subject to GLBA requirements and agree to comply with these requirements through their Program Participation Agreement with the U.S. Department of Education. Institutions are required to safeguard student financial aid information, including implementing administrative, technical, and physical safeguards, and periodically evaluating the effectiveness of those safeguards, including user access controls (16 CFR 314.3 and 314.4). Condition: CLA identified that the University does not meet all the compliance requirements of the GLBA safeguards rule. Questioned costs: None reported. Context: During our testing, we noted that the University did not demonstrate compliance with certain requirements of the GLBA Safeguards Rule related to ongoing monitoring of system access. Cause: The University does not have a process in place to periodically review and evaluate user access controls. Effect: The absence of periodic review of user access controls increases the risk of unauthorized access to sensitive student financial aid information, which could compromise the security andconfidentiality of protected data. Repeat Finding: No. Recommendation: We recommend the University review the GLBA Safeguards Rule and implement appropriate processes and controls to ensure compliance with all applicable provisions. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of the Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 181701 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted that the University was unable to provide evidence that a key control to verify the accuracy and timeliness of payments to program participants had been performed. Questioned costs: None reported. Context: The University was unable to provide documentation evidencing that the key control was performed for any of the 40 disbursements selected for testing. Cause: The University’s procedures for reviewing payments to program participants did not include documentation to provide evidence that the review had occurred. Effect: The lack of documented review increases the risk that errors in payments to program participants may not be identified or corrected in a timely manner. Repeat Finding: No. Recommendation: We recommend the University implement procedures to ensure evidence of the key control review over payments to program participants is documented and retained. View of Responsible Official: There is no disagreement with the audit finding.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203 specifies the annual and aggregate loan limits the Institutions may not exceed for an academic year of study under the Direct Loan program and also requires loans to be prorated for a program of student that is less than a full academic year in length. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.. Condition: During our testing, we noted two students who were awarded incorrect amounts for Subsidized and Unsubsidized Direct Loans. Questioned costs: $1,247 Context: During our testing of forty students, we noted one student was over awarded unsubsidized loans, and a second student was under awarded subsidized loans and over awarded unsubsidized loans. Cause: One student was awarded to an incorrect cost of attendance. A second student was awarded a maximum unsubsidized loan and remaining subsidized loan up to their remaining need. Effect: The University paid one student an amount of loans that was greater than the student was eligible to receive and paid one student an amount of loans that was less than the student was eligible to receive. Repeat Finding: Yes, 2023-001 Recommendation: We recommend that the University review their awarding procedures and implement procedures to ensure direct loans are awarded within student eligibility. View of Responsible Official: The University agrees with the finding.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting. Questioned costs: None reported. Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred. Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2023-002. Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred. View of Responsible Official: The University agrees with the finding.

Criteria or specific requirement: Section 479A of the higher education administration (HEA) gives an institution’s financial aid administrators (FAA) the authority to use professional judgment to adjust, on a case-by-case basis, the cost of attendance or the values of the items used in calculating the expected family contribution (EFC) to reflect a student’s special circumstances. In making case-by-case determinations, the FAA must obtain and retain in the affected student’s file documents supporting and substantiating the reasons for any adjustment. The HEA does not provide a framework for the FAA to calculate the expected student or parent contribution or for the adjusted aid amounts. In addition, the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted that there was no documentation of review of professional judgement issued available. Questioned costs: None reported. Context: During our testing, we noted that one student out of forty had professional judgement issued. We were able to review the documents, however we were unable to see evidence that a review of the professional judgement issuance had been performed by the University. Cause: There was no documentation to show that procedures to review professional judgement decisions were completed. Effect: Failure to assess professional judgement decisions could result in an employee not adequately assessing the students’ needs and leave students underserved. Failure to review verification documents could result in students’ verification not being completed correctly. Repeat Finding: No. Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored. View of Responsible Official: The University agrees with the finding.

Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Questioned costs: None reported. Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available. Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred. View of Responsible Official: The University agrees with the finding.

Criteria or specific requirement: A Direct Subsidized Loan, Direct Unsubsidized Loan, or student Direct PLUS Loan borrower who is graduating, leaving school, or dropping below half-time enrollment is required to complete exit counseling. If the student drops out without notifying the school, the school must confirm that the student has completed online counseling or mail exit counseling material to the student at their last known address. The school may also email the information to the student’s home (not school) email address if the school has it. The school may also send the student a direct link to the exit counseling materials online. Whatever method the school chooses must be used within 30 days of learning that the borrower has withdrawn or failed to participate in an exit counseling session. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted the University did not send notifications of exit counseling to students who graduated or withdrew during the year. Questioned costs: None reported. Context: During our testing of 40 students, we noted exit counseling notifications were not sent out to students during fiscal year 2024. Cause: The University does not have a process in place. Effect: Failure to send exit counseling notifications could result in a student not completing their exit counseling. Repeat Finding: No. Recommendation: We recommend the University implement procedures to ensure exit counseling notifications are sent to students who graduated or withdrew. View of Responsible Official: The University agrees with the finding.

Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: During our testing of disbursements to eligible students, we noted one instance of a Pell award not being properly disbursed. Questioned costs: None reported. Context: In our eligibility sample of 40, one student was not properly disbursed their Pell award. Student was enrolled half-time for fall and winter, and less-than-half time for spring. Student only received a disbursement in fall. Cause: The students award was based on full-time enrollment level, but the student was only enrolled half-time in fall and winter. Pell recalculation was not performed for this student, and remaining aid was not paid. Effect: A student did not receive all their Pell Grant Aid. Repeat Finding: No. Recommendation: We recommend the University review the current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. View of Responsible Official: The University agrees with the finding.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our enrollment reporting testing, we noted the University did not update student enrollment data correctly or timely. Questioned costs: None reported. Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment status for 2 of the 40 students tested. The enrollment effective date of 6 of the 40 students tested was not reported correctly to NSLDS. The status change of 28 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 40 students tested. The program enrollment effective date of 3 of 40 students tested did not match the institutions records. The program enrollment status of 2 of 40 students tested did not match the status per the institution. Cause: The University did accurately report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Additionally, NSC did not report all status changes timely which caused the University to not meet the requirements. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: No. Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. View of Responsible Official: The University agrees with the finding.

Criteria or specific requirement: Under section 2003(5) of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient must use a portion of their institutional funds received under this supplemental award to (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as amended (HEA) (20 USC § 1087tt). In addition, Uniform Grant Guidance (2 CFR 20.303) requires nonfederal entities receiving Federal awards establish and maintain controls designed to reasonable ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted there was no amount allocated to the earmarking requirement. Questioned costs: None reported. Context: During our testing, we noted the University was not in compliance with the annual reporting requirements because the University did not report ARP funds expended to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student or other circumstances, described in section 479A of the HEA. Cause: The policies and procedures of the University did not ensure that annual reporting requirements to report amounts spent for earmarking requirements were accurately met. Effect: The University inaccurately reported the amount spent under earmarking requirements. Non-compliance with federal regulations could lead to funds being required to be returned or refunded in order to meet the reporting requirement. Repeat Finding: No. Recommendation: We recommend the University revise their report to properly show the amount spent under earmarking requirements. In addition, we recommend the University put procedures in place to review earmarking requirements and properly track them for reporting purposes. View of Responsible Official: The University agrees with the finding.

Criteria or specific requirement: At the time an institution makes a TEACH disbursement to a student, it must confirm that the student is eligible for the funds being disbursed (34 CFR 668.164(b)(3)). With the exception of FWS, disbursements are made on a payment period basis and the disbursement must be made during the current payment period (34 CFR 668.164(b)(1)). Condition: During our testing of disbursements to eligible students, we noted one instance of a TEACH award not being properly disbursed. Questioned costs: None reported. Context: In our eligibility sample of 40, one student received a TEACH award. The student did not receive the full award they were eligible for because the student had a four-term budget and the system automatically disburses based on a three-term budget. When a student has more than a three-term budget, the University must manually lock the disbursements. The University did not do that for this student. Cause: The student receiving TEACH funds was enrolled in four-terms, and the system automatically determines disbursements based on a three-term budget. Effect: The University did not disburse the full TEACH funds awarded to an eligible student until it was noted as part of the audit process. Repeat Finding: No. Recommendation: We recommend that the University disburses the remaining award to the student and implement procedures to ensure awards are properly disbursed to students who have more than a three-term budget.

Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.320 and 200.318(i); a nonfederal entity must have procedures that document the rationale for the method of procurement, selection of the contract type, basis for contractor selection, and the basis for the contract price. In addition, the guidance for the micro-purchase threshold is $10,000 unless other provisions have been followed allowing a higher threshold. Condition: During our testing of procurement procedures, we noted one item for which procurement procedures required for items purchased with federal funding were not followed. Questioned costs: None reported. Context: One of six samples tested did not have documentation to support the basis for the contractor selected for a small purchase transaction. Cause: The University did not follow procurement procedures required to be used when purchasing goods or services with federal funds because initially the item was purchased with non-federal funding. At a later time, a portion of the purchases was paid for with HEERF institutional funding. Effect: The University is not in compliance with procurement requirements to properly document the procurement rationale for goods or services paid for with federal funds. Repeat Finding: Yes. Prior year finding 2021-002 Recommendation: We recommend the University revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds. View of Responsible Official: The University agrees with the finding.

Federal agency: Department of EducationFederal program title: Student Financial Assistance ClusterAssistance Listing Number: 84.268 - Federal Direct LoansAward Period: July 1, 2020 to June 30, 2021Type of Finding:-Compliance, Other Matter- Significant Deficiency in Internal Control over ComplianceCriteria or specific requirement: When a student withdraws during a term (or, in a nonterm program, during a payment period), the effective date for the withdrawn ('W') status is the withdrawal date used by the institution in accordance with 34 CRF 668.22(c). In the case of the student who completes a term and does not return for th next term, leaving the course of study uncompleted, the effective date for the 'W' status is the final day of the term in which the student was last enrolled. The description within the NSLDS Enrollment Reporting Guide (and compliance supplement) defines the effective date as: the date that the current enrollment status reported for a student was first effective. The important piece about the effective date is it starts the grace period for loans; therefore, it is necessary for this date to be accurate.Condition: In our sample for forty (40) students selected for the National Student Loan Database System (NSLDS) enrollment reporting testing, there were three (3) total errors. Two (2) students had effective dates per the school's records which did not match the effective date reported in NSLDS. Another student was reported to have been graduated at the enrollment detail level but not at the program level NSLDS.Questioned costs: None reported.Context: The three errors noted in the NSLDS testing included two incorrect effective dates, and one status in the NSLDS enrollment level reporting which did not agree with the program level reporting within NSLDS.Cause: The students noted in this finding of NSLDS enrollment dates not being accurate were due to: unofficial withdrawal errors created by National Student Clearinghouse (NSC) guidance, requiring EOU to not update NSLDS directly for unofficial withdrawals, in addition to student enrollment date being updated by NSC incorrectly.Effect: An accurate reporting of the effective date and change in status is critical for the student's grace period for repayment for their loans. Any errors in status or the effective date of that status impacts when a student would be obligated to start paying back loans.Repeat Finding: Yes. Prior year finding 2020-001.Recommendation: We recommend that the University implement procedures to ensure that changes in status and effective dates within NSLDS match the records of the institution.View of Responsible Official: The University agrees with the finding.

Federal agency: Department of EducationFederal program title: Education Stabilization Fund (ESF)Assistance Listing Number: 84.425F - HEERF Institutional PortionAward Period: July 1, 2020 to June 30, 2021Type of Finding:-Compliance, Other Matter- Significant Deficiency in Internal Control over ComplianceCriteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.320 and 200.318)i); a nonfederal entity must have procedures that document the rationale for the method of procurement, selection of the contract type, basis for contractor selection, and the basis for the contract price. In addition, the guidance for the micro-purchase threshold is $10,00 unless other provisions have been followed allowing a higher threshold.Condition: Two of four samples tested di dnot have documentation to support the basisi of the contractor selected for small purchase transactions at the time the procurement was transacted. The purchases were both for the same vendor. In addition, the University uses a mocro-purchase threshold of $25,000, but were not able to provide a copy of the letter approving this higher dollar threshold.Questioned costs: None reported.Context: The University does not have procedures in place to ensure procurement transactions are properly documented the required elements of the procurement process. In addition, the University could not find the letter from their cognizant agency approving this higher dollar micro-purchase threshold.Cause: The University does not have a process in place to document the decisions ade in the procurement process in determining the appropriate vendor. The University obtained the approval for the higher micro-purchase threshold several years ago and could not locate it.Effect: The University is not in compliance with procurement requirements to properly document the procurement rationale for the decisions made in the procurements. The University is using a micro-purchase threshold but does not have a letter to support the approval of this higher threshold.Repear Finding: NoRecommendation: We recommend the University revise their processes to establish procedures that will ensure procurement policies are properly followed and documented. We also recommend the University obtain a copy of the approval letter from their cognizant agency.View of Responsible Official: The University agrees with the finding.

Federal agency: Department of EducationFederal program title: Education Stabilization Fund (ESF)Assistance Listing Number: 84.425F - HEERF Institutional PortionAward Period: July 1, 2020 to June 30, 2021Type of Finding:-Compliance, Other Matter- Significant Deficiency in Internal Control over ComplianceCriteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6, a nonfederal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended or otherwise excluded.Condition: Four of four samples tested did not have suspension and debarment procedures performed. Some of these were purchases made from the general fund and transferred to another fund to be paid with ESF funding.Questioned costs: None reported.Context: The University does not have procedures in place to document the verification/certification that vendors have not been suspended or debarred.Cause: The University does not have a process in place to ensure suspension or debarment is not violated for covered transactionsEffect: The University could enter into a covered transaction with a vendor who is suspended or debarred.Repeat Finding: No.Recommendation: We recommend the University create a process to document suspension and debarment procedures for any vendors that they spend $25,000 or more.View of Responsible Official: The University agress with the finding.

Federal agency: Department of EducationFederal program title: Education Stabilization Fund (ESF)Assistance Listing Number: 84.425F - HEERF Institutional PortionAward Period: July 1, 2020 to June 30, 2021Type of Finding:- Significant Deficiency in Internal Control over ComplianceCriteria or specific requirement: The 2 CFR section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal awards.Condition: During our testing of reporting, we noted four of five student reports and one of three institutional reports tested did not have documentation that the reports had been reviewed.Questioned costs: None reported.Context: During our testing of reporting, we did not note any noncompliance. However, we noted the University did not have documentation to provide evidence that the published reports had been reviewed.Cause: The University does not have a process in place to ensure evidence of review of the published reports is maintained.Effect: The University could publish/submit a report that is not reviewed that may contain errors.Repeat Finding: No.Recommendation: We recommend the University institute a formal control over the reporting process that includes documentation of the review of reports published/submitted.View of Responsible Official: The University agrees with the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.268 ? Federal Direct Loans Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: When a student withdraws during a term (or, in a non-term program, during a payment period), the effective date for the withdrawn (`W?) status is the withdrawal date used by the institution in accordance with 34 CFR 668.22(c). In the case of the student who completes a term and does not return for the next term, leaving the course of study uncompleted, the effective date for the `W? status is the final day of the term in which the student was last enrolled. The description within the NSLDS Enrollment Reporting Guide (and compliance supplement) defines the Effective Date as: the date that the current enrollment status reported for a student was first effective. The important piece about the effective date is it starts the grace period for loans, so if a student is an unofficial withdrawal and the school uses 50% of the term for R2T4, then that date should be the effective date within NSLDS as well. Condition: In our statistically valid sample of forty (40) students selected for NSLDS enrollment reporting testing, there were seven total errors. Four students had effective dates per the school's records which did not match the effective date reported in NSLDS. There were two students with an incorrect status reported to NSLDS. Lastly, there was one student reported as withdrawn on the enrollment detail in NSLDS but reported as 3/4 time in the program-level NSLDS. Questioned costs: None reported. Context: The seven errors noted in the NSLDS testing included four incorrect effective dates, two incorrect status levels reported, and one status in the NSLDS enrollment level reporting which did not agree with the program level reporting within NSLDS. Cause: The students noted in this finding of NSLDS enrollment dates not being accurate were due to; unofficial withdrawal errors created by NSC guidance, requiring EOU to not update NSLDS directly for unofficial withdrawals; timing of data uploads to NSC for later graduate records due to a data script error in the upload file from EOU; and one student enrollment date being updated by NSC incorrectly. Effect: An accurate reporting of the effective date and change in status is critical for the student's grace period for repayment of their loans. Any errors in status or the effective date of that status impacts when a student would be obligated to start paying back loans. Repeat Finding: No Recommendation: We recommend that the University implement procedures to ensure that changes in status and effective dates within NSLDS match the records of the institution. View of Responsible Official: The University agrees with the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.063 ? Federal Pell Grant and 84.268 ? Federal Direct Loans Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Federal regulations require all student enrollment status changes be reported to the National Student Loan Database System (NSLDS) using the proper enrollment status, effective date of the change, and be reported within 30 days of the change, unless a scheduled reporting with the change is to occur in the next 60 days from the later of the school becoming aware or the actual change in enrollment. Condition: Enrollment status changes were reported with improper statuses and were not reported timely. Questioned costs: None reported. Context: One of 40 students tested in our statistically valid sample was reported to NSLDS with an incorrect status. Two of the 40 students tested were not reported in a timely manner to NSLDS based on the time the University became aware of the change in status. Cause: The University schedule of reporting status changes has some gap time at the end of each term that allows the possibility of students changing status within that "gap" time to not be timely reported. Lack of proper procedures around reporting graduating students. Effect: The University is not in compliance with the federal regulations that require accurate enrollment statuses and changes to those status be reported to NSLDS within a timely manner. This could result in changes to the amount of interest charged to a student along with improper length of grace periods for students. Repeat Finding: No Recommendation: We recommend the University put a process in place to ensure that enrollment status changes be reported accurately and timely for all graduated students and if degrees are to not be completed within 60 days of the end of a student?s last term the student be reported as withdrawn and subsequently updated to graduated when the degree is awarded to the student. In addition, the University should revise their submission schedule to ensure all dates a student could withdraw would be included in a report to be filed within 60 days. View of Responsible Official: The University agrees with the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.007 ? Federal Supplemental Education Opportunity Grants (FSEOG) Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over ComplianceCriteria 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 awarded to this student was $600. Questioned costs: None reported. Context: During our eligibility testing, we noted one student out of 40 students tested in a statistically valid sample, who was awarded FSEOG funds with a non-zero EFC. In this same population, we noted 7 students with a zero EFC who did not receive FSEOG that would have otherwise been eligible. Cause: The student originally had a zero EFC but after the verification process their EFC increased to 1508, effectively causing this student to no longer be the neediest of students to receive the funding. The student file had been locked down and therefore did not update the EFC to capture the verification changes. 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: Yes, 2018-002 Recommendation: We recommend the University evaluate their procedure for secondary oversight, when EFC changes are made during the verification process. Secondary oversight would ensure that students with the greatest financial need receive FSEOG before other eligible students with the lowest EFC receive FSEOG. View of Responsible Official: The University agrees with the finding. While this is listed as a repeat finding, due to FSEOG being paid to a non-zero EFC student, the procedural errors that caused these issues were very different. 2018 was due to an inaccurate data pull selection due to the overlapping years in the first year of FAFSA opening date on October 1st, 2017, and 2019 was due to not removing the FSEOG code after an increase in EFC during a verification change.

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