The Howard UniversityHigher Education

FINDING 2025-005 Federal Program Information: Federal Pell Grant Program (ALN: 84.063); Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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 which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (“CIP”) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics “(NCES”). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. Condition: The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions: • For 21 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days. • For 4 of 40 campus level records tested, the University did not accurately report the students’ enrollment effective date. • For 22 of 40 program level records tested, the University did not certify the students’ enrollment data within 60 days. • For 8 of 40 program level records tested, the University did not accurately report one or more program enrollment data elements. • Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple repeat errors during the 2025 fiscal year. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-003. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS. Views of Responsible Officials: The Enrollment Reporting process is supervised by the University Registrar and the Registrar is responsible for providing enrollment files to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submit the enrollment file report to the National Student Loan Database System (NSLDS). Howard moved to Workday Student as the University’s ERP beginning with the Fall 2024 semester and enrollment reporting to NSC was processed solely through Workday. with the Fall 2024 semester and enrollment reporting to NSC was processed solely through Workday. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” there would be no configuration issues that affect compliance. It was not possible for the Registrar’s Office to fully test enrollment reporting prior to "go live" due to students needing to be registered in courses to send a test file to NSC. At the start of the Fall 2024 semester, Howard worked closely with National Student Clearinghouse to troubleshoot issues that could delay the enrollment files transmission in August and September 2024. This setup of the one-time migration between Workday and NSC was not completed timely. The appropriate individuals from the Registrar’s Office, Office of Financial Aid, National Student Clearinghouse are working together to enable ongoing communication and monitoring of reporting requirements. These parties will work together to confirm student enrollment statuses are reported timely and accurately. The transition to Workday Student allowed the University to review each program of study to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program start date and program length are reported to NSLDS. The effective enrollment date reflected in NSLDS for the four students with the incorrect program start date was fed from the University’s prior ERP, Banner, and all program start dates have now been accurately updated in Workday. The implementation of Workday and staffing transitions in the Registrar's Office caused delays in students being cleared for graduation and then to NSC. The issue for Graduate reporting should not recur due to resolved implementation issues with Workday. Monthly enrollment reporting schedules were set up in NSC for the 2025-2026 academic year during Summer 2025. These enrollment reporting schedules will be updated each summer for the upcoming academic year. Graduation files are scheduled to be transmitted on the first of every month to National Student Clearinghouse. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day reporting timeline will be met. The Office of the Registrar is in constant communication with the representative from NSC when there are questions on reporting student enrollment statuses accurately. Bi-semester reviews by the Associate Director for Compliance will ensure any potential issues in reporting are identified and resolved timely. A review of students reported to NSC for Spring 2025 was completed with a specific focus on students who had a change in enrollment. This review discovered the Workday configuration did not pick up students who dropped courses during the semester in the enrollment file. This configuration issue in Workday has now been corrected. A review of students’ enrollment status for Fall 2025 after the University’s drop/add period showed students in the enrollment reporting file were reported correctly on the Fall 2025 First of Term enrollment file sent to NSC.

FINDING 2025-006 Federal Program Information: Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements to or on Behalf of Students – General Disbursement Criteria – Federal Work-Study Program – In accordance with 34 CFR 675.19(b)(2)(i), the institution must establish and maintain fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day. Condition: Certain Federal Work-Study (“FWS”) payments were not adequately supported by the respective time records. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with recordkeeping requirements. Questioned Costs: None. Context: For 4 of 40 FWS payments tested, the FWS timesheets did not support FWS earnings for pay period tested. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-005. Recommendation: We recommend the University enhance its internal controls, policies and procedures to ensure that student timesheets are appropriately reviewed.   Views of Responsible Officials: The Offices of Undergraduate Studies, Financial Aid, Human Resources, and Payroll have worked to re-configure our Enterprise Resource Planning system, Workday, to significantly reduce early time approval and minimize incorrect time attribution. We introduced new controls on May 7, 2025, and provided additional training throughout Academic Year 2024-2025. Although we have made much progress, we are still working to minimize FWS program risks. Specifically, we have noticed that retrofitting the staff and faculty hiring system may not be an ideal solution for handling the unique needs of the Federal Work Study program. As such, we are working with our official Workday partner to enact a distinct student hiring portal, that will also leverage Workday. We expect that this portal will be more nimble and better able to address FWS program management and controls. The expected launch date is Fall 2026.

FINDING 2025-007 Federal Program Information: Student Financial Assistance Cluster (Various ALN’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP. Condition: The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures. Cause: Insufficient internal controls and administrative oversight with respect to FISAP reporting. Effect or Potential Effect: The University is not in compliance with special reporting requirements. Questioned Costs: None. Context: The University was unable to provide documentation corroborating the amount reported for Federal Perkins Loan Program cash on hand. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-006. Recommendation: We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials: Federal Perkins Loan program records are traditionally paper based, as a result, these school records can often be inconsistent. Due to inconsistent data transfer during Howard University’s move from Campus Partners to ECSI (Educational Computer Systems, Inc.) as the Perkins Loan servicer after the 2013-2014 academic year, the University’s Perkins disbursement data did not match the records Howard had from ECSI. In 2022, the University began to work with ECSI on converting the Howard internal records to match ECSI’s records. In mid-April 2026, ECSI notified Howard that the conversion of ECSI Perkins disbursement data to Howard disbursement data was complete. Currently, the adjustments ECSI made to match Howard are being reviewed by the Associate Director for Compliance in Enrollment Management, and feedback will be provided to ECSI. Matching Perkins Loan data between Howard and ECSI will strengthen the data consistency on the FISAP. The consistency of Perkins Loan data between ECSI and Howard University on the FISAP will also assist in strengthening internal controls for determination of the Cash on Hand amount. ECSI works with schools whose general ledger Cash on Hand does not match what is on the FISAP in Part III. It was conveyed by ECSI that it is more important to have awareness of what data does not match and why than to have parity. After the conversion of Perkins data from ECSI has been approved, the Associate Director for Compliance will meet with Director of Accounting to begin the process of reviewing Perkins wind-down procedures and the accounting related. Howard University is in the process of liquidating the Federal Perkins Program. Due to staffing changes, the Director of Student Billing and Engagement, is now responsible for the Federal Perkins Loan liquidation process. The University is working with ECSI and the Department of Education to complete the liquidation. As part of the liquidation process, the Director of Billing and Engagement contacted the Department of Education to determine the remaining steps for Perkins liquidation. 13 Perkins Loans remaining need to be assigned. Howard is in the process of determining if these loans can be assigned to ED or if the school will need to purchase them.

FINDING 2025-008 Federal Program Information: Student Financial Assistance Cluster (Various ALN’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check. Condition: The University did not refund credit balances to certain students within the required timeframe. Cause: Insufficient internal control and administrative oversight with respect to the disbursement of federal awards. Effect or Potential Effect: The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance. Questioned Costs: None. Context: For 3 of 25 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-007. Recommendation: We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.   Views of Responsible Officials: Beginning with the Fall 2024 semester, Howard University transitioned from using Ellucian Banner to Workday as the University’s ERP. The Bursar’s Office was not able to fully test the Title IV refunds process prior to "go live" due to the inability to disburse and create refunds to be sent to the University’s bank, JP Morgan. In August 2024, the Bursar’s Office identified configuration issues with JP Morgan where parents were not associated with students’ IDs and addresses in delivered refund files sent to JP Morgan Chase. These Title IV checks and direct deposits could not be sent to parents until JP Morgan completely migrated to Workday, in September 2024. After this date, there have not been issues with the JP Morgan Chase configuration with Workday. Workday is a date-driven ERP. Meal charges for Spring 2025 were placed on the students’ account, the due date for payment on the referenced meal charges was put in Workday as 12/23/2025 instead of 12/23/2024. This due date is when the charge is factored into the application of payments for the Office of the Bursar. The result was that housing charges were not being applied for the Spring 2025 semester until the error was discovered by the University during reconciliation. These meal charge dates were corrected to 12/23/2024 in March 2025. Internal controls have been created where there is a second level of review of due dates for charges placed on the students’ account. Due dates for charges during a semester are now reviewed by the Bursar and Housing to ensure the application of payments will pick up all charges for a semester. There are also continuing corrective actions being taken to best capture students who were eligible for a Title IV refund and deliver Title IV credit balances to students within the 14-day timeframe, including the use of reports available in Workday. Beginning with Fall 2025 semester, the on-demand “SF Refund Review Report” in Workday is used to identify students that are eligible for a Title IV refund. Howard University staff meet daily with Workday consultants from AVAAP to provide feedback and discuss any current issues experienced in Workday. The goal of these meetings is to have a constant flow of information on what is working effectively and what is not working effectively within Workday. There are also more Howard University staff focused on the Title IV credit balance process and more stages of approval required for the process to be completed. A list of Title IV credit balance refunds is captured from the “SF Refund Review Report,” the settlement run of refunds are reviewed by the refund approver in the Office of the Bursar, then the refund listing goes to the University Bursar for approval. After approval by the University Bursar the listing of students who will receive Title IV refunds by direct deposit and/or check is sent to the Treasury Specialist for approval. Once the Treasury Specialist approves the refunds, the Cash Manager approves the transmittal of this information to JP Morgan, and the funds are then transmitted to JP Morgan for delivery to parents and students. There has also been identification of a backup employee in the Bursar’s Office and Treasury responsible for the Title IV refund process. These backups have been trained so there is no disruption to the workflow, and they are currently running the Title IV credit balance delivery process when there is a workload balance need to do so to ensure timely refunds. Bi-semester internal reviews by the Associate Director for Compliance in Enrollment Management have taken place which complement the additional levels of review put in place by the Bursar. An internal review of 10 Title IV refunds sent to students for Summer 2025 was completed in July 2025. A review of 100 students who received refunds for Summer 2025 and Fall 2025 was completed in August 2025. All the students who received a refund for the Fall 2025 semester had their Title IV credit balance delivered timely. A review of 86 Title IV refunds for Fall 2025 completed in October 2025 showed that 0 students in the sample received their Title IV refund past the 14-day timeline.

FINDING 2025-009 Federal Program Information: Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan, FPL funds, or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account. Condition: Certain loan disbursement notifications were not sent timely. Cause: Insufficient internal controls and administrative oversight with respect to loan disbursement notifications. Effect or Potential Effect: The University is not in compliance with loan disbursement notification requirements. Questioned Costs: None. Context: For 3 of 60 loan disbursements selected for testing, the notification was not sent to the borrower within the required timeframe. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-008. Recommendation: We recommend the University enhance its internal controls, policies and procedures over loan disbursement notifications to ensure that such notifications are sent to students and/or parents within the required timeframe. Views of Responsible Officials: Beginning with the Fall 2024 semester, Howard University transitioned from using Ellucian Banner to Workday as the University’s ERP. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” in Fall 2024 there would be no configuration issues that affect compliance. Workday was not configured to send out Parent Plus Loans, therefore, Parent Plus notifications were as the result sent out as part of a manual process through the Financial Aid email box. Research into the issue and continued discussions with Workday consultants determined that Parent Plus disbursement notifications definitively cannot be sent out automatically after disbursement in Workday as a result of a flaw in Workday’s configuration capabilities. As a result, “FA CR Parent PLUS Disbursement Notification” report is run weekly out of Workday to identify all Parent Plus Loan disbursements, and a notification is sent to the parent’s email address on file through the Financial Aid Loans team email box. The three disbursement notifications that were not sent out within the 30-day timeline resulted from these Parent PLUS Loans not being shown on the “FA CR Parent PLUS Disbursement Notification” report. These disbursement notifications were originally sent to the student’s email address through Workday instead of being sent to the parent’s email address. While these disbursement notifications were sent timely, a compliance review of disbursement notifications discovered the Workday configuration was sending out some Parent PLUS Loan disbursement notifications to the student’s email address. This left the PLUS disbursement off the “FA CR Parent PLUS Disbursement Notification.” Upon discovery of this configuration error, the Loans Team worked with the University’s Workday consultant to prevent any Parent PLUS Loan disbursement notifications from being sent out through Workday. Bi-semester internal reviews by the Associate Director for Compliance in Enrollment Management are ongoing. The error with Parent PLUS Loan notifications being sent to the wrong individual in Workday was identified in the March 2025 disbursement notification compliance review. An August 2025 review of disbursement notifications for medical students resulted in there being no disbursement notifications found that were sent past the 30-day timeline and they were sent to the correct individuals. A September 2025 review of disbursement notifications was completed and resulted in enhancements to the mail merge template used to manually send out the Parent PLUS Loan disbursement notifications. An updated mail merge template was created, tested and implemented. A November 2025 disbursement notification review was completed to ensure the Parent PLUS notifications went out timely and to the parent’s email address.

FINDING 2025-010 Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Financial Reporting – Federal regulations (34 CFR 668.164(b)(3)(iii)) require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Items considered key in student origination records, if applicable, are: award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Condition: For certain students identified through our testing, the University did not report disbursements through the COD website within the required timeframe. Certain origination records contained inaccurate data. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: The University was not in compliance with COD reporting requirements. Failure to submit and update COD records in a timely manner could result in improper awards of Title IV funds. Questioned Costs: None. Context: • For 3 of 60 disbursement records tested, the University did not timely report the disbursement to COD. • For 4 of 60 origination records tested, the University did not accurately report all key items. Identification as a Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend the University enhance its procedures and internal controls to ensure timely and accurate reporting of Title IV disbursements. Views of Responsible Officials: Beginning with the Fall 2024 semester, Howard University transitioned from using Banner to using Workday as the University’s ERP. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” during Fall 2024 there would be no configuration issues that affect compliance. It is not possible for Financial Aid to fully test the COD disbursement reporting process prior to "go live" due to the inability to send test disbursement files to COD for reporting purposes. Once Howard disbursed loans and was able to send actual disbursement files to COD, the Enrollment Management Systems Analyst worked to identify and resolve outstanding issues. Initial reporting of disbursements to COD began on August 6, 2025. When the first disbursement file was sent to COD, the EM Systems Analyst identified the file schema sending out disbursements from Workday to COD kept rejecting the entire file. The Systems Analyst worked with the University Workday consultants to resolve the rejections and was able to correct the issue on August 28th. The cause of the rejected files between Workday and COD was an underlying Workday system issue that was corrected an updated released by Workday. There were issues in Workday regarding the school code that were identified which delayed a small cohort of students’ disbursements from being reported to COD. The Howard University enrollment school code is 00144800 and NSC required a “dummy” school code to be used for enrollment reporting of Graduate and Professional students. This “dummy” code was 00144880. A small cohort of students had loans that were rejected due to Workday reporting the 00144880 school code to COD instead of the 00144800 school code. Reconciliation identified the students and once the enrollment code sent to COD was corrected in Workday, the loan was accepted. The cost of attendance variance was a result of unfamiliarity with the Workday system. After a student's aid has been originated and disbursed, Workday will not automatically send the disbursement file back out to COD, which was not an issue Howard encountered when using Ellucian Banner. In Workday, when a student’s cost of attendance changes due to cost of attendance increase or the student’s housing status must be adjusted, there is manual intervention required. Students who have a change to their cost of attendance need to have a flag checked off in the origination record. This will allow the updated cost of attendance to be reported in COD when the next disbursement file is sent to COD. The current process is when a student's cost of attendance is manually adjusted, the flag for the record to be sent to COD is checked off in the origination record. The Associate Director for Compliance has completed internal compliance reviews testing whether disbursements are being sent to COD within 14 days. Thus far, no issues have been found in these reviews. Files are transmitted to COD at least four times per week and rejected disbursements are worked to meet the 14-day disbursement reporting timeline. A compliance review has been initiated to ensure the cost of attendance reported out of Workday matches the cost of attendance in COD.   Howard University staff meet daily with Workday consultants from AVAAP to provide feedback and discuss any current issues experienced in Workday. The goal of these meetings is to have a constant flow of information on what is working effectively and what is not working effectively within Workday. This process is documented and staff are trained.

FINDING 2025-011 Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48). Condition: The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 3 of 10 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation supporting an appropriate procurement process. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: While we acknowledge that this represents a repeat finding, the Corrective Action Plan conveys a multi-year remediation strategy that focuses on policy transparency, system controls, staffing capacity, training, and accountability mechanisms. The University will continue to address the execution and adoption challenges across Accountable Units. Since the prior audit cycle, the University has strengthened preventive controls to eliminate reliance on post-transaction modifications or corrections. The Corrective Action Plan addresses policies and procedures, OPC capacity and expertise, training and outreach, monitoring, and accountability. The Corrective Action Plan is structured to reduce reliance on detective measures and facilitate preventive compliance. Consequently, the University expects future audit cycles to yield favorable results.

FINDING 2025-012 Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: We noted the following exceptions: • For 1 of 19 equipment purchases tested, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership. • For 6 of 19 equipment purchases tested, the respective property record was either missing an asset identifier, or the asset identifier did not match the physical asset tag. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-010. Recommendation: We recommend that the University strengthen controls over federally owned equipment by ensuring all applicable equipment is promptly and appropriately tagged to indicate federal ownership in accordance with federal regulations. In addition, the University should enhance procedures for maintaining property records by ensuring that disposition information is timely, accurate, and complete. This should include clearly defined roles and responsibilities, documented review and reconciliation processes, and periodic monitoring to ensure equipment records remain current and compliant with federal property management requirements. Views of Responsible Officials: Since the prior audit period, the University implemented comprehensive corrective actions, including policy updates, strengthened receiving and tagging controls, enhanced supervisory review in WorkDay, and ongoing communications with Suppliers and internal stakeholders. Detective and corrective controls have been established through quarterly exception reporting, monthly equipment purchase audits, and completion of a University-wide physical inventory, and required follow-up to locate, tag, or correct asset records. Moreover, the corrective action plan aims to establish an integrated, sustainable control environment. With documented procedures, active monitoring, customer communications, training, and management oversight, the University expects future audit cycles to yield favorable results.

FINDING 2025-013 Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: Certain publications did not include proper acknowledgment of funding or disclaimer as required. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: For 3 of 8 publications tested, the publication did not include the required acknowledgement of support or disclaimer. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-011. Recommendation: We recommend that the University implement formal procedures and controls to verify that publications supported by federal awards appropriately acknowledge funding sources and include required disclaimers prior to release. Management should document review and approval of publications and periodically monitor compliance to ensure adherence to sponsor and federal requirements. Views of Responsible Officials: Federal awards require that all publications resulting from federal grant support, including conference presentations, promotional materials, agendas, and internet sites, include an acknowledgment of federal support and a disclaimer that the contents reflect the authors' responsibility and not that of the sponsoring agency. As this is a repeat finding, the University has undertaken a comprehensive, multi-pronged corrective strategy to ensure sustained compliance going forward. Responsibility for publication acknowledgment and disclaimer compliance now resides with the Sponsored Programs Office (SPO) Pre-Award, in collaboration with the University Library. Key actions completed to date include: a formal Standard Operating Procedure finalized and approved in November 2025; mandatory publication compliance training with a required 80% passing score, serving as a prerequisite for new award setup effective November 2025; a Principal Investigator (PI) Acceptance Memo requiring signature within five business days of each award kickoff meeting to reinforce PI awareness of publication responsibilities; quarterly compliance communications issued to all federally funded PIs; and a dedicated publication compliance category added to the OOR ticketing system to streamline intake and support documentation. During Award Kickoff Meetings, acknowledgment and disclaimer requirements specific to each award are reviewed directly with the PI. SPO Pre-Award and the University Library conduct ongoing reviews of federally funded publications using available bibliometric tools, with periodic spot checks. PIs who do not meet training requirements are subject to a hold on proposal submissions until compliance is verified.

FINDING 2025-014 Federal Program Information: Research and Development Cluster (various ALN #’s), USAID Foreign Assistance for Programs Overseas (ALN 98.001), Charles B. Rangel International Affairs Program (ALN 19.020) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings certifications. In addition, documentation to support certain cost allocations could not be provided. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed or appropriately monitored during the six-month period ended June 30, 2025. Questioned Costs: None. Context: • For the Research and Development Cluster, 19 of 40 employees tested did not complete a time and effort certification for the period selected. • For the Charles Rangel Program, 9 of 10 employees tested did not complete a time and effort certification for the period selected. • For the USAID Program, 6 of 10 employees tested did not complete a time and effort certification for the period selected. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-012. Recommendation: We recommend that the University strengthen its internal controls over effort certifications for federally funded grants by establishing formal procedures to ensure timely completion, review, and monitoring of required certifications. This should include clearly defined roles and responsibilities, automated reminders or tracking mechanisms, periodic management review to identify missing or overdue certifications, and documented follow up procedures to ensure compliance with federal requirements supporting payroll costs charged to federal awards as required. Views of Responsible Officials: The University initiated the Effort Certification process to capture the full calendar year 2025 in April 2026. This represents a one-time extended certification period designed to include previously uncertified periods that had concluded, specifically the second half of FY25 (January–June 2025) and the first half of FY26 (July–December 2025). In May 2025, the non-accounting functions of Grants and Contracts Accounting at Howard University were transitioned to the Office of Research, Sponsored Programs Office. During this organizational transition, the University prioritized the completion and accuracy of all costing allocations to ensure payroll data was complete and reliable for effort certification purposes. This period was also utilized to identify and resolve any backlog of costing allocations and award charges and stabilize the Office of Research. Addressing these items ensured that effort reflected complete and accurate payroll activity, thereby enabling Principal Investigators to appropriately review and certify their effort. The Sponsored Programs Office (SPO) now leads post-award financial oversight and collaborates with Human Resources (HR) and Finance to ensure designated personnel are identified and granted system access to enter costing allocations and labor cost transfers in Workday. In addition, in response to the auditor’s recommendation to enhance internal controls and ensure timely monitoring of effort reporting, Howard University has implemented the following corrective actions: Hired Dedicated Departmental Support – Six College Research Administrators (CRAs) and an Associate Director of CRA’s were hired to support high-volume research colleges. The CRAs ensure timely and accurate labor cost transfers, effort certification, and costing allocation entries during award setup and throughout the award lifecycle.   Enhanced Effort Reporting Process – SPO will lead improvements to the effort certification process, including: • Advance communication to PIs, CRAs, and Deans outlining certification deadlines • Clear guidance on when labor cost transfers may occur outside the certification cycle • Reinforcement that all effort changes must be reflected in the effort system to ensure alignment with payroll. • Training – Targeted training will be delivered to Principal Investigators, CRAs, and other research stakeholders to support consistent application of policies and procedures. Monitoring and Oversight – Monthly and quarterly reconciliation reports will be developed to track and validate timely and accurate payroll allocations for research personnel.

FINDING 2025-015 Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - per 2 CFR Part 200.305(b)(3), when the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the federal agency or pass-through entity reasonably believes the request to be improper. M. Subrecipient Monitoring – per 2 CFR Part 200.332(e)(1), a pass-through entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must review financial and performance reports. Additionally, in accordance with 2 CFR 200.332(g), a pass-through entity must verify that a subrecipient is audited as required by Subpart F of Part 200. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. The University was unable to provide documentation evidencing appropriate, annual review of its subrecipients’ Single Audit reports. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: The University was not in compliance with the requirements for pass-through entities. Questioned Costs: None. Context: • For 3 of 23 subrecipient payments tested, the University was unable to provide documentation evidencing appropriate review by the principal investigator. • For 6 of 23 subrecipients payments tested, payment was not made within the required timeframe. • For 7 of 7 subrecipients tested, the University was unable to evidence its verification of whether an audit had been performed. Identification as a Repeat Finding: This is a repeat of prior year finding 2024-013. Recommendation We recommend that the University enhance subrecipient monitoring controls by implementing documented invoice review protocols and enforcing annual audit verification procedures for all subrecipients. Management should define responsibilities for these reviews, document oversight activities performed, and implement monitoring controls to ensure compliance with federal subrecipient monitoring requirements. Views of Responsible Officials: In response to the auditor’s recommendation to enhance internal controls and ensure timely review of invoice protocols and subrecipient monitoring, Howard University is implementing the following: • The University is currently piloting a new Supplier Invoice Portal, launched jointly by the Sponsored Programs Office and the Office of Procurement, to improve invoicing efficiency and compliance. Under this new process, subrecipients will be required to submit invoices electronically in accordance with the terms and conditions of their subawards. The portal will support a streamlined review and approval process, with invoices routed through an automated workflow to ensure timely review and disbursement. • To support completion of the University’s annual audit verification requirements for subrecipients, oversight will occur at multiple stages throughout the subaward lifecycle. This includes reviewing audit reports at the proposal development stage, during which subrecipients are required to complete a Subrecipient Commitment Form (implemented September 2025) prior to proposal submission. • At the award stage, refreshed due diligence will be conducted, including a re-review of the subrecipient’s Single Audit and/or financial statements. Finally, the Post Award Compliance team will perform an annual review of subrecipients’ audit reports and complete audit follow up procedures as necessary.

FINDING 2025-016 Federal Program Information: USAID Foreign Assistance for Programs Overseas (ALN 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: Certain expenditures were not converted using an appropriate exchange rate. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: Overpayment of federal funds. Questioned Costs: Below reportable threshold. Context: For 2 of 25 expenditures tested, the University used an inaccurate exchange rate in its reimbursement claims. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance review controls over reimbursement claims to ensure accurate exchange rates are consistently applied and supported by appropriate documentation. Views of Responsible Officials: Monthly Settlement Reports are used to reconcile actual expenses. An outdated spreadsheet was previously used to convert travel expenses, which resulted in incorrect exchange rate calculations. The team has implemented an updated conversion process. Going forward, the Sponsored Program Office Team will review and approve the exchange rates to ensure they are reasonable, accurate, and applied consistently.

FINDING 2025-017 Federal Program Information: Student Financial Assistance Cluster (ALN: Various), Research and Development Cluster (ALN: Various), Annual Appropriation (ALN 84.915A), Constitutional Law Chair Endowment (ALN 16.000), Matching Endowment (84.000), Law School Clinical Endowment (ALN 84.998D), USAID Foreign Assistance for Programs Overseas (ALN 98.001), Charles B. Rangel International Affairs Program (ALN 19.020) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - According to federal regulations (2 CFR 200.512(a)(1)), the audit, the data collection form, and the reporting package must be submitted within 30 calendar days after the auditee receives the auditor’s report(s) or nine months after the end of the audit period (whichever is earlier). Condition: The University did not submit the June 30, 2025 Single Audit to the Federal Audit Clearinghouse by the required deadline. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with Single Audit reporting deadlines. Questioned Costs: None. Context: The University did not submit the June 30, 2025 Single Audit to the Federal Audit Clearinghouse by the required deadline. Identification as a Repeat Finding: This is a repeat of prior year finding 2024-002. Recommendation: We recommend that the University strengthen its internal controls over the Single Audit reporting process to ensure required audit reports are submitted to the Federal Audit Clearinghouse and respective cognizant agencies in accordance with federal deadlines. This should include establishing a formal compliance calendar, clearly defining roles and responsibilities for report submission, implementing management review and approval procedures prior to filing, and performing periodic monitoring to ensure compliance. Views of Responsible Officials: In response to the auditor’s recommendation to strengthen internal controls and ensure timely submission of the Single Audit Report to the Federal Audit Clearinghouse, Howard University will enhance cross collaboration across the University to improve audit readiness. During the May 2025 transition from the Grants and Contracts Accounting Office to the Sponsored Awards Office, the University experienced significant staff turnover and a loss of institutional knowledge, which contributed to audit readiness challenges. Since that time, the University has focused on stabilization efforts. The Office of Research Sponsored Programs has been restructured and is now almost fully staffed. The University will be establishing monthly check ins with key stakeholders to ensure adherence to a compliance calendar with clearly defined roles and responsibilities across core compliance areas. Additionally, the University has hired a Director of Post Award Compliance and Training to lead audit readiness efforts, strengthen internal controls, and support ongoing monitoring and compliance throughout the fiscal year.

FINDING 2025-018 Federal Program Information: USAID Foreign Assistance for Programs Overseas (ALN 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - 2 CFR §200.305(b)(1) indicates that advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. Condition: The University was unable to fully reconcile advance payments received from the sponsor to certain expenses incurred during the year. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with cash management requirements. Questioned Costs: None. Context: For 4 of 25 expenditures tested, the University was unable to reconcile the expenditure to the related sponsor payments received. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls over compliance to ensure that cash draws are properly reconciled to expenditures. Views of Responsible Officials: The University receives advance payments from the sponsor, with the amount determined by the sponsor and adjusted as financial reports are submitted by the University. In response to the auditor’s recommendation to strengthen internal controls, Howard University will implement procedures to document and reconcile all cash payments received from sponsors on a quarterly basis to actual expenses incurred. This reconciliation process will help ensure that sponsor payments are fully accounted for and appropriately matched to related expenditures, thereby enabling the University to clearly demonstrate which expenses have been reconciled to payments received.

Federal Program Information: University Transportation Centers Program (ALN 20.701) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients with fiscal year ends of June 30, 2023 to submit Single Audit reports to the Federal Audit Clearinghouse within the required time frame. Condition: Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation. In addition, the University did not submit the June 30, 2023 Single Audit to the Federal Audit Clearinghouse by the required deadline. Cause: Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Submission of the University’s fiscal year 2023 Single Audit was delayed due to the resulting investigation. Effect or Potential Effect: These costs were inappropriately reimbursed with federal funds during the year. The related investigation also resulted in the University not submitting its 2023 Single Audit to the Federal Audit Clearinghouse within the required timeframe. Questioned Costs: $196,258 Context: As discussed in Finding 2024-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2024 that identified both the suspected misappropriation and the related questioned costs. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-002. Recommendation: We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations. Views of Responsible Officials: Accounts Payable (AP) will create a Corrective Action plan to include the following. 1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to University policies and grant terms. PRFs will be reviewed by SPO and Grants and Contracts Accounting (GCA) and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. 2. AP is working with Enterprise Technology Services (ETS) to modify the Workday Ad Hoc Business process to require additional review by PI, SPO, and GCA before payments can be issued. Each approval role will receive guidance regarding 3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.

Federal Program Information: Federal Pell Grant Program (ALN: 84.063); Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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 which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (“CIP”) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics “(NCES”). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.   Condition: The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions: • For 2 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days. • For 2 of 40 campus level records tested, the University did not accurately report the students’ enrollment effective date. • For 2 of 40 program level records tested, the University did not certify the students’ enrollment data within 60 days. • For 13 of 40 program level records tested, the University did not accurately report one or more program enrollment data elements. • Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2024 fiscal year. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-003. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS. Views of Responsible Officials: The Enrollment Reporting process is supervised by the University Registrar and is responsible for transmitting enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submits the enrollment status report to NSLDS. The University Registrar resigned in July 2024 and the Associate Registrar position was also vacant at that time. These “peak time” staffing issues helped create confusion as to which enrollment files had been scheduled and sent to NSC. 1 of the 2 findings where the University did not certify the students’ enrollment data within 60 days was due to volume at NSC and deemed out of institutional control. Based on email correspondence with the Compliance Team at the National Student Clearinghouse, it was determined, “For the delay between DV file being submitted by Howard University to NSC 08.27.2024 and processed by NSC 09.16.2024, I assess this was due to volume on NSC side at the time and outside institution control.” The University hired an experienced Associate Director Registrar for Compliance in December 2024 and is currently searching for a University Registrar with experience working in the Workday Enterprise Resource Planning system (ERP). Howard moved to using Workday Student as the University’s ERP beginning Fall 2024 and it has been confirmed the accurate program lengths for each program were entered in Workday. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program lengths are reported to NSLDS. Screenshots of the programs reported to NSLDS incorrectly have been provided to BDO as a way to document the program length will be accurately reported in the future. Graduation files are scheduled to be transmitted on the first of every month to NSC. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day timeline will be met. In Workday, the date the student has been cleared for graduation (i.e. the effective day) is available on the “Academics” tab. This should make it easier to show an audit trail for the student’s graduation clearance date.

Federal Program Information: Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame. Cause: Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. While amounts were within allowable thresholds, certain funds were overdrawn and held in excess of the allowable time frame. Questioned Costs: None. Context: Two instances of excess cash that were not eliminated within the allowable time frame were identified for the Federal Work-Study Program for the year ended June 30, 2024.   Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-004. Recommendation: We recommend the University continue to enhance its internal controls, policies and procedures to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to ED. Views of Responsible Officials: A statement of procedure and workflow will be implemented to formally reconcile FWS - Title IV expenses to the general ledger on a monthly basis to ensure timely draws and adjustments. Adjustments and updates to the FISAP including prior year adjustments will be included in the Title IV reconciliation process and communicated immediately. The reconciliations will require two-tier approvals.

Federal Program Information: Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements to or on Behalf of Students – General Disbursement Criteria – Federal Work-Study Program – In accordance with 34 CFR 675.19(b)(2)(i), the institution must establish and maintain fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day. Condition: Certain time records were prematurely approved by the students’ supervisors prior to the performance of the work by the students being completed. In addition, an instance was identified in which a student was not paid at least once per month as required. Cause: Insufficiently designed internal controls and administrative oversight with respect to FWS disbursements. Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with recordkeeping requirements. Questioned Costs: None. Context: • For 4 of 40 Federal Work-Study (“FWS”) payments tested, the University reviewed and approved students’ timesheets before time was incurred. • For 1 of 40 FWS payments tested, the student was not paid within the required timeframe. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-008. Recommendation: We recommend the University enhance its internal controls, policies and procedures to ensure that student timesheets are appropriately reviewed. Views of Responsible Officials: Federal Work Study (FWS) supervisors are required to have training on the appropriate policies and procedures when hiring a FWS student. They sign off on the Federal Work Study supervisor agreement stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours, as this is a not a best practice. The Center for Career & Professional Success began using this updated FWS supervisor agreement beginning with the Spring 2025 semester. All FWS supervisors who had students for Fall 2024 were required to review and sign the updated agreement as well. The Federal Work Study Coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works. The Federal Work Study Coordinator also ensures supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. The full-time Federal Work Study Coordinator position was filled prior to the end of the Fall 2024 semester, and this ensures a full-time employee is now in place to help provide a more active review of the Federal Work Study program. One student was not paid FWS earnings within 30 days. At the time, Howard University did not print out paper checks, only providing FWS payments as a direct deposit. The student was to be paid for those two pay periods (10/8/23-10/21/23 and 10/22/23-11/4/23) on 11/3/23 and 11/17/23. The student did not have any payment selections set up in the system for the earnings to be deposited into and this delayed the receipt of the Federal Work Study payment. Working with the AVP for Enrollment Management, we have discussed with Payroll the need to process a paper check if a student chooses this delivery method. The University is also working on an awareness campaign that will encourage students to set up their direct deposit information in Workday. Students understanding the need to set up direct deposit and the willingness to process paper checks, if necessary, should prevent this finding from recurring. The Associate Director for Compliance or designee will review when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working during class hours. These reviews of FWS hours matching the students’ earnings will provide another layer of oversight.

Federal Program Information: Student Financial Assistance Cluster (Various ALN’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP. Condition: The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures. Cause: Insufficient internal controls and administrative oversight with respect to FISAP reporting. Effect or Potential Effect: The University is not in compliance with special reporting requirements. Questioned Costs: None. Context: The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-006. Recommendation: We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.   Views of Responsible Officials: Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University. Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31. Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity. It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP. The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.

Federal Program Information: Student Financial Assistance Cluster (Various ALN’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check. Condition: The University did not refund credit balances to certain students within the required timeframe. Cause: Insufficient internal control and administrative oversight with respect to the disbursement of federal awards. Effect or Potential Effect: The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance. Questioned Costs: None. Context: For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.   Views of Responsible Officials: There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023. The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.

Federal Program Information: Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan, FPL funds, or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account. Condition: Certain loan disbursement notifications were not sent timely. Cause: Insufficient internal controls and administrative oversight with respect to loan disbursement notifications. Effect or Potential Effect: The University is not in compliance with loan disbursement notification requirements. Questioned Costs: None. Context: For 16 of 40 loan disbursements selected for testing, the notification was not sent to the borrower within the required timeframe. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls, policies and procedures over loan disbursement notifications to ensure that such notifications are sent to students and/or parents within the required timeframe. Views of Responsible Officials: Howard University uses automated processes to identify and send loan disbursement notifications to parents and students. The nightly UC4 process prompted Banner to send out a Direct Loan notification to the student and/or parent. This UC4 process showed all students who had a Direct Loan disbursement after the last nightly UC4 process was run. During a compliance review of disbursement notifications during the Fall 2023 semester and the Loans Team worked with Banner consultants to determine the reason for this. While this issue was being reviewed and a solution created, the Loans Team used the RLRDLDD report in Banner, which is a report that showed all loans disbursed. This report could be matched against the UC4 listing of loans disbursed. This check between UC4 and the RLRDLDD report was used to send out loan notifications that was missed during the UC4 process during the Fall 2023 semester. During a Spring 2024 compliance review of disbursement notifications, it was discovered the RLRDLDD report was missing disbursements as well. As a corrective action, the Loans Team then began using a loan audit report out of the Argos reporting system to identify students who may have a disbursement not included in the UC4 and/or RLRDLDD report. The support time required for maintenance of Banner was also reduced due to the ongoing integration and implementation efforts to prepare Workday for the Fall 2024 semester. This increased the length of time it took to correct the UC4 process and RLRDLDD reports. Howard no longer uses Banner to send out Graduate PLUS, Subsidized and Unsubsidized loan notifications. Workday now is now responsible for sending out the disbursement notification after a loan has disbursed and there is a record in the student’s Activity History to document the loan notification has been sent. Parent PLUS Loan notifications must be sent out manually due to Workday not having the capability to send a disbursement notification to the parent’s email on file. The “FA CR Parent PLUS Disbursement Notification Report” is run weekly out of Workday to identify all Parent Plus Loan disbursements and a notification is sent to the parent’s email address on file. Bi-semester reviews are completed by the Associate Director for Compliance to ensure the loan disbursement notifications are being sent to students and parent in the required 30-day timeline. These reviews also ensure inclusion in the loan notification of all federally required information.

Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48). Condition: The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement compliance requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.   Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following. 1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed. 2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions. 3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel. 4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.

Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: We noted the following exceptions: • For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership. • For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following. 1. Updating the following policies: • Asset Capitalization Policy • Sponsored Program Equipment Management Policy 2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols 3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday. 4. Implement an asset management platform to track assets throughout the organization. 5. Require intermittent inventory by PIs to confirm assets are available and in use. 6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number." 7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.

Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.

Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.

Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.   Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.

Federal Program Information: University Transportation Centers Program (ALN 20.701) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): G. Matching - According to the grant agreement, a non-federal match of not less than 50% of the Federal funds paid by the grantor to the grant recipient under this grant is required as a condition of the grant. Condition: The University was unable to provide documentation showing that its cost share requirement had been met. Cause: Insufficient internal controls and administrative oversight with respect to cost share/matching requirements. Effect or Potential Effect: The University was not in compliance with the mandated matching requirements. Questioned Costs: None. Context: The University was unable to provide documentation supporting that its cost share requirement had been met for the program. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and procedures to ensure that matching funds are appropriately tracked. Views of Responsible Officials: Due to the ongoing U S Department of Transportation investigation, the awarded grants cost share is on hold. Once the investigation is concluded, Howard University will meet the cost share obligations and requirements.

Federal Program Information: Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): § 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs: a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding. b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”). B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. Condition: Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation. Cause: Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: These costs were inappropriately reimbursed with federal funds during the year. Questioned Costs: $141,060. Context: As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations. Views of Responsible Officials: The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025. As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.

Federal Program Information: Federal Pell Grant (ALN: 84.063); Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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 which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (“CIP”) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics “(NCES”). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. Condition: The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions: • For 7 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days. • For 1 of 40 campus level records tested, the University did not accurately report the students’ enrollment effective date. • For 5 of 40 campus level records tested, the University did not accurately report the students’ enrollment status. • For 1 of 25 program level records tested, the University did not accurately report the students’ program begin date. • For 5 of 25 program level records tested, the University did not accurately report the students’ enrollment status. • For 4 of 25 program level records tested, the University did not accurately report the students’ program length of study. • For 2 of 25 program level records tested, the University did not accurately report the students’ CIP code. • Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2023 fiscal year. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-002. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS. Views of Responsible Officials: The Enrollment Reporting process is supervised by the University Registrar and is responsible for providing enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (“NSC”), who then submits the report to NSLDS student’s enrollment status. The University is committed to ensure sufficient training and support to the Office of the Registrar to keep the institution in compliance. While the expectation is the University will hire an experienced University Registrar and Associate Director Registrar for compliance, continued training opportunities will be made available through National Student Clearinghouse and NASFAA (National Association of Student Financial Aid Administrators). The reported data is for students who are ¾ time during a semester, “3Q,” was discovered through testing of enrollment reporting samples to not be set up correctly in Banner. This has resulted in students who are taking between 9-11 credits being reported as “H” for half-time instead of “3Q” for three-quarter time. The newest University Registrar set up the “3Q” status correctly in Banner in January 2024 and testing of enrollment reporting samples show the 3Q status is accurate. The students in the program and campus-level findings should now be accurately reported as “3Q.” After speaking with the Executive Director of Academic Planning and Curriculum, the CIP codes for the program identified as findings had not been updated when all CIP codes were updated in 2020. She also confirmed the length of the program was incorrectly published on the site for these programs. Howard has moved to Workday Student as the University’s Enterprise Resource Planning system and the accurate CIP codes and program lengths were confirmed. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday. The University Registrar was not aware the FSA Audit testing exempt range of 07-19-2022 through 02-28-2024 required students who had an enrollment change during that period to be updated. This audit exemption range was abnormal, and the University hired a new Registrar during this time period, which resulted in there being no knowledge transfer the enrollment changes had not been updated. Graduation files are now being sent monthly to the National Student Clearinghouse to avoid students not being picked up for graduation as they are cleared.

Federal Program Information: Federal Supplemental Educational Opportunity Grant (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame. Cause: Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. While amounts were within allowable thresholds, certain funds were overdrawn and held in excess of the allowable time frame. Questioned Costs: None. Context: One instance of excess cash that was not eliminated within the allowable time frame was identified for each of the University’s campus-based programs for the year ended June 30, 2023.   Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-004. Recommendation: We recommend the University continue to enhance its procedures to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to the Department of Education. Views of Responsible Officials: The University will continue to provide additional information and training to personnel outside of the Office of Financial Aid. This information and training – where applicable – will be used to ensure that the University’s policies and procedures are in line with federal regulations and that internal policies and procedures do not supersede or impede federal regulations.

Federal Program Information: Federal Pell Grant (ALN: 84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Financial Reporting – Federal regulations require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, COA, and the “Academic Start Date” and “Academic End Date”. Condition: For certain students identified through our testing, the University did not submit Federal Pell Grant payment data through the COD website within the required timeframes. Cause: Insufficient internal controls and administrative oversight resulted in the untimely reporting of certain Federal Pell Grant payment data. Effect or Potential Effect: The University is not in compliance with COD reporting requirements. Failure to submit and update COD records in a timely manner could result in improper awards of Title IV funds. Questioned Costs: None. Context: For 1 for 25 students selected for disbursement testing, the University did not report the Federal Pell Grant disbursements to COD within the required time frame. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University ensure that disbursement records are submitted to COD no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations.   Views of Responsible Officials: This student’s Pell disbursement was not reported within 15 days of disbursement due to the COD (Common Origination Disbursement) system rejecting the student’s disbursement. These Pell rejects are worked through the reconciliation process and this exception was not worked in a timely manner, resulting in COD accepting the disbursement past the 15-day deadline. The Howard University employee who was completing reconciliation of Title IV funds, as well as responsible for working through any Pell rejected disbursements is no longer employed at Howard. The Assistant Director for Compliance works in the Office of Financial Aid and responsible for completing reconciliation and working any Pell rejected disbursements. The Associate Director for Compliance in Enrollment Management reviews reconciliations and ensures any rejected disbursements are resolved within the 15-day timeframe.

Federal Program Information: Student Financial Assistance Cluster (Various ALN’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP. Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures. Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame. Effect or Potential Effect: The University is not in compliance with special reporting requirements. Questioned Costs: None. Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP. Identification as a Repeat Finding: No similar findings identified in the prior year.   Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.

Federal Program Information: Student Financial Assistance Cluster (Various ALN’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed. Cause: Insufficient internal controls and administrative oversight with respect to verification procedures. Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: None.   Context: We noted the following exceptions: • For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures. • For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements. Identification as a Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations. Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.

Federal Program Information: Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements to or on Behalf of Students – General Disbursement Criteria – Federal Work-Study Program – In accordance with 34 CFR 675.19(b)(2)(i), the institution must establish and maintain fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day. Condition: Certain time records were prematurely approved by the students’ supervisors prior to performance of the work by the students. Cause: Insufficiently designed internal controls and administrative oversight with respect to FWS disbursements. Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with recordkeeping requirements. Questioned Costs: None. Context: For 5 of 40 Federal Work-Study payments tested, the University reviewed and approved students’ timesheets before the time was incurred. Identification as a Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that student timesheets are appropriately reviewed. Views of Responsible Officials: Federal Work Study supervisors are required to have training on the appropriate policies and procedures when hiring a Federal Work Study student. They will sign off on a document stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours. The student’s hours work may match the pay the student received and was approved for, but it is against policy to approve hours before the student worked. FWS supervisors will sign they understand this. The Federal Work Study coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works and ensuring supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. Due to turnover in the department, a full-time FWS coordinator had not been hired and the person responsible for reviewing the hours worked had additional responsibilities outside of monitoring Federal Work Study. A full-time Federal Work Study Coordinator position has been approved and the anticipation is this position will be filled prior to the end of the Fall 2024 semester. The Associate Director for Compliance will include a review of when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working-class hours. This plan to include when the supervisor approved the hours should provide another layer of oversight.

Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48). Condition: The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.   Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-006. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures. OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.

Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged as required. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: We noted the following exceptions: • For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. • For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system. • For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system. • For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-007. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept. Views of Responsible Officials: Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data. In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.

Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: • For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-008. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications. Action Steps: 1. Communication a. Create Current Researcher Email List Serv for distribution of information/reminders. b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements. c. We will distribute information regarding this finding to our researchers every quarter via the listserv. d. Completion: The first distribution will occur on October 1, 2024 2. Develop Training Materials a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications. b. Include examples of compliant and non-compliant publications. c. Completion: Second Quarter of FY 2025 3. Campus-Wide Training a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method. b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project. c. Completion: Second Quarter of FY 2025 4. Award Specific Training a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.   5. Ongoing Monitoring and Compliance a. Maintain records of all training attendance. b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications. c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements. d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.

Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Cause: Insufficient internal controls and administrative oversight with respect to the University’s effort certification process. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely. • For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-012. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding. A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary. Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions. Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.

Federal Program Information: Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards. Condition: The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner. Cause: Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Questioned Costs: None. Context: We noted the following in during our testing: • For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records. • For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-010. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements. Views of Responsible Officials: Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.

Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.

Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.

Federal Program Information: Provider Relief Fund (ALN: 93.438) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - Per Uniform Guidance, ?200.510(b), the auditee shall prepare a schedule of expenditures of Federal awards (the ?Schedule?) for the period covered by the auditee's financial statements. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the Schedule easier to use. At a minimum, the Schedule should list individual Federal programs by Federal agency and provide total Federal awards expended for each Federal program during the entity?s fiscal year. Condition: During our audit procedures, we noted that the University did not complete the Schedule timely, and it was also not properly reviewed by management prior to being provided for audit purposes. Cause: Insufficient internal controls and administrative oversight with respect to the timely preparation and review of Schedule. Effect or Potential Effect: Lack of appropriate and timely review by management increases the risk that the amounts, contract, or grant names, Assistance Listing Number (?ALN?) information, and classification of the awards presented on the Schedule are presented incorrectly. Questioned Costs: None. Context: The initial Schedule received excluded certain federal expenditures related to the Provider Relief Fund that were applicable to the year ended June 30, 2022. The exclusion of this federal program was due to insufficient administrative oversight as well as a lack of communication and coordination between the University and its subsidiary, Howard University Hospital (the ?Hospital?). The inclusion of these expenditures on the current year SEFA resulted in an additional major program that was required to be tested. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University implement additional internal controls and enhance their current policies and procedures to enable grants and contracts personnel to effectively maintain a detailed Schedule that contains the correct amounts, contract or grants names, ALN information and classification of the awards, which can be more readily reconciled to the underlying general ledger detail prior to receipt by the auditors. We also recommend that grants and contracts personnel at the University have frequent communication with the applicable Hospital personnel to ensure that all federal expenditures incurred and federal awards received during the year are appropriately reflected within the Schedule as required. Views of Responsible Officials: The Office of Grants and Contracts will update the policies and procedures to include a detailed, timely and accurate submission of federal expenditures in accordance with the Uniform Guidance, ?200.510(b) to reflect on the annual SEFA. Quarterly meetings and annual reviews will be established with appropriate Howard University Hospitals? personnel to ensure required expenditures are included on the SEFA per federal requirements. Sr. Director of Grants and Contracts and the Controller will prepare the SEFA going forward and will receive formal approval by the Controller.

Federal Program Information: Federal Pell Grant (ALN: 84.063); Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (?FFEL?) loan programs via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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 which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code ? The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. Condition: The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University?s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions: ? For 10 of 40 campus level records tested, the University did not certify the students? enrollment data within 60 days. ? For 4 of 40 campus level records tested, the University did not notify the Department of the students? enrollment changes. ? For 6 of 40 campus level records tested, the University did not accurately report the students? enrollment status. ? For 2 of 25 program level records tested, the University did not notify the Department of the students? graduated status. ? For 4 of 25 program level records tested, the University did not accurately report the students? enrollment status. ? Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2022 fiscal year. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS. Views of Responsible Officials: The Enrollment Reporting process is supervised by the Office of the Registrar (Registrar), which is responsible for providing enrollment reports to Howard University?s third-party servicer, National Student Clearinghouse (NSC), who then submits the report to the National Student Loan Data System (NSLDS). The departure of a key registrar personnel resulted in miscommunication and neglect of the enrollment reporting duties. The issue has since been remedied, but due to the time lag, will take an additional fiscal year for improvements to be observed.

Federal Program Information: Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Disbursements To or On Behalf of Students ? Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan, FPL funds, or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Certain parent PLUS loan borrowers were not notified of loan disbursements to their dependent?s account. Additionally, the University was unable to provide documentation evidencing that notifications were sent to certain borrowers. Cause: Insufficient internal controls and administrative oversight with respect to loan disbursement notifications. Effect or Potential Effect: The University is not in compliance with loan disbursement notification requirements. Questioned Costs: None. 118 Context: ? For 6 of 40 students selected for testing who received a Federal Direct PLUS loan, while the University notified the student within the required timeframe, notification was not sent to the parent borrower as required. ? For 2 of 40 students selected for testing, the University was unable to provide documentation confirming that a notification was sent and thus, we were unable to determine whether notifications were made within the required timeframe. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-005. Recommendation: We recommend the University enhance its procedures and internal controls over loan disbursement notifications to ensure that such notifications are sent to students and/or parents within the required timeframe. Views of Responsible Officials: Loan disbursement notifications are now the responsibility of the Office of Financial Aid (Financial Aid). Notifications are now being sent out through Ellucian Banner (Banner) when a student has been awarded. The disbursement notification documentation is now electronic and does not require manual actions from Howard University employees to be completed. The following areas identified in the audit have been addressed: ? Notifications are immediately sent out electronically when the student is awarded, allowing Howard to meet the required notification timeline for notification. ? Each notification is addressed to the specific person (i.e., parent, student) who is responsible for paying back the loan. ? The name of the student, exact amount of the disbursement and the date of disbursement is generated on the notification as well. Bi-semester reviews have been completed by the Associate Director for Compliance (Financial Aid) to ensure the loan disbursement notifications are being generated in the required timeline and includes all federally required information listed above in each notification. Spring 2022, Summer 2022, and Fall 2022 reviews have been completed thus far with no significant issues identified. The policies and procedures for loan disbursement notifications were updated in April 2022. These will be reviewed annually.

Federal Program Information: Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution?s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student?s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the ?ED?) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution?s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. While amounts were immaterial, certain funds were overdrawn and held in excess of the allowable time frame. Questioned Costs: None. Context: Several instances of Federal Direct Loan funds drawn and held in excess of the allowable time frame were identified throughout the University?s fiscal year. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-006. Recommendation: We recommend the University continue to enhance its procedures to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to the Department of Education. Views of Responsible Officials: The finance and financial aid divisions will collaborate to improve the internal controls that are in place to ensure there is a three-day turnaround for draws and refunds. The policies and procedures for cash management were updated in July 2022.

Federal Program Information: Federal Direct Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date the school issued the check. Condition: The University did not refund credit balances to certain students within the required timeframe. Cause: Administrative oversight with respect to the disbursement of federal awards. Effect or Potential Effect: The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance. Questioned Costs: None. Context: For 1 of 25 students selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that Title IV credit balances are paid timely to students. Views of Responsible Officials: There was one credit balance in the sample (from September 2021) that was not processed within 14 days. It was completed on the 20th day after the refund was created on the student?s account. Note that the record identified in the sample was during the time of the cyberattack. While this does not absolve Howard of demonstration of administrative capability, the bursar team could not have performed their function during this time.

Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Cause: Insufficient internal controls and administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: For 9 of 13 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-009. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The Office of Procurement and Contracting (OPC) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 prior to issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University?s Procurement Policy and procedures. OPC revised the University?s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. Training for Research Administrators and Principal Investigators is scheduled for April and May 2023.

Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: Certain federally funded equipment was not appropriately tagged to indicate Federal ownership. Cause: Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 1 of 4 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-010. Recommendation: We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately maintained and that adequate records are kept. Views of Responsible Officials: The University experienced challenges from the cyber-attack in September 2021 that impacted the transition to the Workday ERP. Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.

Federal Program Information: Research and Development Cluster (ALN: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 9 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-011. Recommendation: We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included. Views of Responsible Officials: The Vice President for Research will establish procedures to adhere to federal regulations requiring appropriate acknowledgements and disclaimers for federally funded publications including presentations, papers, posters, flyers, press releases, etc. The Vice President for Research will communicate the appropriate federal regulations to the Principal Investigators and staff regarding publications. Also, the Vice President for Research will maintain and monitor publications by updating the publication portal to be used by all Principal investigators. The link to the updated disclosure is https://research.howard.edu/research/research-tools/federal-sponsor-requirementsacknowledging- funding. The link was updated as of 08/2022.

Federal Program Information: Education Stabilization Fund (?ESF?) (ALN: 84.425E and 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - There are three components to reporting for ESF: 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. Institutions must report publicly on their primary websites on a quarterly basis for both student portion and institutional portion funds. Condition: The University did not appropriately prepare their ESF quarterly reports during the year ended June 30, 2022. Quarterly reports were also not posted to the University?s website timely. Additionally, the University was unable to provide documentation supporting that the ESF annual report was submitted as required. Cause: Insufficient internal controls and administrative oversight with respect to Reporting requirements. Effect or Potential Effect: The University did not comply with the requirements of Reporting. Questioned Costs: None. Context: We noted the following exceptions: ? For 2 of 2 quarters selected for testing, the University did not prepare certain ESF Institutional Portion quarterly reports using the appropriate reporting form. Additionally, the University was unable to provide documentation supporting that quarterly reporting information was posted to the University?s website within 10 days of each quarter end. ? For 2 of 2 quarters selected for testing, the University?s quarterly public reporting of its Student Aid Portion expenditures did not include information identified as key by the Department. ? The University was unable to provide documentation supporting the accurate and timely submission of the ESF annual report. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-012. Recommendation: We recommend the University enhance its procedures and internal controls over the applicable ESF reporting requirements to ensure reports are submitted timely and accurately. Views of Responsible Officials: On March 21, 2023, Howard assigned Ms. Sammara Evans, the Director of Institutional Research, as the lead for quarterly and annual HEERF reporting. The areas with access to the information required to complete the quarterly and annual HEERF reporting have now been added to the Education Stabilization Fund (ESF) site as editors. This list of editors on the ESF site includes representatives from the Financial Aid Office, the Bursar?s Office, Enrollment Analytics and Grants & Contracts. These offices can now receive notifications regarding submission deadlines and have access to update the information for each report. Prior to the quarterly or annual report due date, the Director of Institutional Research will request the necessary information from each department and is aware of her responsibilities to do so. HEERF reporting responsibilities have been defined.

Federal Program Information: USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the schedule of expenditures of federal awards. Condition: The University is not in compliance with certain requirements of Reporting. Certain progress and financial reports were not submitted in a timely manner. Questioned Costs: None. Context: We noted the following in during our testing: ? For 2 of 5 USAID reports selected for testing, the progress and/or financial report was not submitted timely to the respective awarding agency. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely. Cause: Administrative oversight with respect to Reporting requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University properly follow its policies and procedures over the applicable compliance requirements of the Reporting requirement to ensure that all required reporting requirements are met in accordance with federal regulations as well as the grant agreements. Views of Responsible Officials: To ensure financial reports and invoices are submitted timely, the Office of Grants and Contracts will implement hard-stop cutoff dates for receiving supporting documentation used to prepare financial reports and invoices. Financial reports and invoices will continue to be submitted timely and accurately. Progress reports will be submitted in accordance with the required federal regulations accurately and timely.

Federal Program Information: Annual Appropriation Supplemental Funding (ALN: 84.915A) and Education Stabilization Fund (?ESF?) Institutional Portion (ALN: 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - When awards provide for advance payments, recipients must follow procedures to minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement. Cash advances to a recipient organization shall be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the recipient organization in carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the recipient organization for direct program or project costs. C. Cash Management ? Education Stabilization Fund ? ESF requires that Student Aid Portion should be disbursed within 15 calendar days of the drawdown from ED?s G5 grants system and Institutional Aid Portion should be disbursed within 3 calendar days of the drawdown from G5. Condition: The University did not disburse ESF Institutional Portion funding within 3 calendar days of drawdown. Additionally, the University drew down Annual Appropriation Supplemental Funding related to lost revenue prior to the completion of the lost revenue calculation. Questioned Costs: None. Context: The University did not disburse ESF Institutional Portion funding within 3 calendar days of drawdown. Additionally, the University drew down Annual Appropriation Supplemental Funding related to lost revenue prior to the completion of the lost revenue calculation. Effect or Potential Effect: The University is not properly following its established policies and procedures to ensure that compliance is maintained with respect to the Cash Management compliance requirements. Cause: Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls to comply with the Cash Management requirements associated with is drawdowns of federal funds. Views of Responsible Officials: The original lost revenue calculation was completed by the Deputy Chief Financial Officer in August 2021. The calculation was reviewed by the Controller and Assistant Treasurer prior to drawing funds. The lost revenue calculation was compiled by management before the draw was completed on 09/09/2021. Deloitte was contracted for an additional review of the lost revenue increasing the lost revenue from $23M to $29M. Howard University will continue to comply with cash management policies and procedures in accordance with ALN: 84.915A.

Federal Program Information: Research and Development Cluster (various ALN #?s), Charles B. Rangel International Affairs Program (ALN: 19.020), USAID Foreign Assistance for Programs Overseas (?USAID?) (ALN: 98.001) and Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Questioned Costs: None. Context: We noted the following in during our testing: ? For 16 of 22 Research and Development Cluster employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 7 of 7 Charles B. Rangel International Affairs Program employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 5 of 5 USAID employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. ? For 2 of 3 Health Workforce for the 21st Century employees selected for testing, an effort certification supporting the employees? payroll costs was not completely timely. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Cause: Insufficient internal controls and administrative oversight with respect to the University?s effort certification process. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: Workday implementation challenges and the September cyberattack caused delays in allocating personnel earnings to grants during the first half of the fiscal year. As a result, certificates were not generated for employees with unallocated earnings for the first six-month reporting period. Certificates were issued on an ad-hoc basis as earnings were allocated. This issue was resolved for the second half of the fiscal year. To further address this finding, Grants and Contracts will adjust the effort certification process to expand the pool of secondary approvers, improve the user interface, and allow for easier reassignments of certificates. In addition, a training module will be developed to assist employees during their review.

Federal Program Information: Education Stabilization Fund (?ESF?) Institutional Portion (ALN: 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed - ESF Institutional Portion funds may be used to defray expenses associated with coronavirus (including lost revenue, reimbursement for expenses already incurred, technology costs associated with a transition to distance education, faculty and staff trainings, and payroll) and to make additional financial grants to students. ESF funds may also have been used to carry out student support activities authorized by the HEA that address needs related to coronavirus. Construction and Real Property Expenditures under ESF (a)(2) subprograms: Under the Consolidated Appropriations Act, 2022, as of March 15, 2022, ESF (a)(2) program subgrantees may expend their ESF (a)(2) grant funds on construction and real property for projects that are connected to the purpose of the ESF program to ?prevent, prepare for, and respond to coronavirus.? Any ESF (a)(2) grantees taking advantage of this flexibility will have to receive approval from the Department of Education for their specific construction and real property projects supported by ESF (a)(2) grant funds. ESF (a)(2) grantees cannot use their (a)(2) grant funds on construction or real property associated with facilities related to athletics, sectarian instruction, or religious worship. B. Allowable Costs/Cost Principles - Grantees are prohibited from using ESF funding for the acquisition of real property or construction. This includes using ESF grant funds on capital projects, including deferred maintenance and capital improvement. However, this general prohibition on construction and acquisition of real property does not extend to activities that meet the definition of ?minor remodeling?. Minor remodeling means minor alterations in a previously completed building, for purposes associated with the coronavirus. The term also includes the extension of utility lines, such as water and electricity, from points beyond the confines of the space in which the minor remodeling is undertaken but within the confines of the previously completed building. The term does not include permanent building construction, structural alterations to buildings, building maintenance, or repairs. Condition: Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Indeterminable. Context: 1 of 40 ESF Institutional Portion expenditures selected for testing were not allowable under the federal award as they were used for construction, maintenance and/or repairs. The University was unable to provide supporting documentation that these costs were specifically connected to purposes associated with the coronavirus and/or that approval was received from the Department of Education prior to disbursement. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-013. Recommendation: We recommend that the University enhance its internal controls and procedures surrounding the review of expenditures charged to federal grants to ensure expenditures are allowable under the federal awards. Views of Responsible Officials: Grants and Contracts will implement a two-tier review process to ensure expenditures charged to the HEERF grant are allowable and in accordance with the Department of Education policies and procedures. Additionally, any expenditures requested and/or transferred to the HEERF grant will require the two-tier review/approval process.

Federal Program Information: Health Workforce for the 21st Century (ALN: 93.266) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs ? In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. Condition: Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: $29,909. Context: For 1 of 25 Health Workforce for the 21st Century expenditures selected for testing, costs charged to the federal award were erroneously duplicated. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures and internal controls surrounding review of expenditures charged to federal grants to ensure expenditures are allowable based on the grant agreement and federal regulations. Views of Responsible Officials: The Controller?s Office and Grants and Contracts will work with Accounts Payable to ensure that payments to vendors are applied timely in Workday. Accounts payable will be required to review all wire requests to ensure the invoices have not been previously paid by check prior to initiating wires.

Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):N. Special Tests and Provisions - Enrollment Reporting - The University is required to update students? statuses on the National Student Loans Data System (?NSLDS?) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days.Condition:The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University?s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe.Cause:Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.Effect or Potential Effect:The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.Questioned Costs:None.Context:? For 4 of 40 students sampled whose status changed during the fiscal year, the University failed to submit a timely notification to the NSLDS website.? For 7 out of 40 students sampled whose status changed during the fiscal year, the University was unable to provide documentation that an accurate notification was submitted to the NSLDS website.? For 8 of 40 students sampled whose status changed during the fiscal year, The University failed to report an accurate enrollment status.? For 6 of 15 error reports received during the year, error records identified in Error/Acknowledgment files were not corrected within the required timeframe.Identification as a Repeat Finding:This is a repeat finding from prior year. This was reported as finding 2020-007 in the prior year schedule of findings and questioned costs.Recommendation:We recommend that the University properly follow its policies and procedures and enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe and error records are corrected and submitted timely.

Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):N. Special Test and Provisions ? Disbursements To or On Behalf of Students - Award Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan, FPL funds, or TEACH Grants.Condition:For certain students who received disbursements of Federal Direct Loan funds, the University did not notify the student or parent of their award disbursement within the required time frame after crediting the student?s account.Cause:Insufficient internal controls and administrative oversight with respect to student aid award notifications.Effect or Potential Effect:The University is not in compliance with award notification requirements.Questioned Costs:None.Context:? For 3 of 40 students selected for testing who received Federal Direct PLUS Loan funds, the University did not properly notify the parent borrower as required.? For 14 of 40 students selected for testing, the University did not include the disbursement date and/or amount in the award notification as required.? For 13 of 40 students selected for testing, the University was unable to provide documentation confirming that an award notification was sent and thus, we were unable to determine whether notifications were made within the required timeframe.Identification as a Repeat Finding:This is a repeat finding from prior year. This was reported as finding 2020-008 in the prior year schedule of findings and questioned costs.Recommendation:We recommend the University enhance its internal controls over award notifications to ensure that such notifications are sent to students and/ or parents within the required timeframe.

Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution?s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student?s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the ?ED?) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution?s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).Condition:Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame and/or allowable thresholds.Cause:Administrative oversight regarding Cash Management compliance requirements.Effect or Potential Effect:The University should continue to enhance its policies and procedures in place to ensure that compliance is maintained with respect to the Cash Management. As a result, while amounts were immaterial, certain funds were overdrawn or held in excess of the allowable time frame and/or allowable thresholds.Questioned Costs:None.Context:Several instances of Federal funds drawn and held in excess of the allowable time frame and/or thresholds were identified throughout the University?s fiscal year.Identification as a Repeat Finding:This is a repeat finding from prior year. This was reported as finding 2020-012 in the prior year schedule of findings and questioned costs.Recommendation:While improvements have been made, we recommend that the University continue to enhance its procedures to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to the U.S. Department of Education.

Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):N. Special Tests and Provisions ? Borrower Data Transmission and Reconciliation - Direct Loans - Federal regulations (34 CFR 690.83 and 685.301) require that the University submit Common Origination and Disbursement (?COD?) information for students in an accurate and timely manner (no earlier than 7 days before and no later than 15 days after disbursement of funds).Condition:For certain students identified through our testing, the University did not submit Federal Direct Student Loans payment data through the COD website within the required timeframes.Cause:Administrative oversight resulted in the untimely reporting of certain Federal Direct Loans payment data.Effect or Potential Effect:The University is not in compliance with COD reporting requirements. Failure to submit and update COD records in a timely manner could result in improper awards of Title IV funds.Questioned Costs:None.Context:For 1 of 40 students selected for disbursement testing, the University did not report the Federal Direct Loan disbursements to COD within the required time frame.Identification as a Repeat Finding:No similar findings noted in the prior year.Recommendation:We recommend the University ensure that disbursement records are submitted to COD no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations.

Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):N. Special Tests and Provisions ? Disbursements to or on Behalf of Students - General Disbursement Criteria ? Federal Work-Study Program - For students receiving Federal Work-Study (?FWS?) Program funds, federal regulations (34 CFR 675.16) require that the University pay FWS compensation at least once a month. Before an institution makes an initial disbursement of FWS compensation to a student for an award period, the institution must notify the student of the amount of funds the student is authorized to earn, and how and when the FWS compensation will be paid. Regardless of who employs the student, the institution is responsible for ensuring that the student is paid for work performed.Condition:For certain students identified through our testing, the University did not pay the student FWS compensation based on their hours worked. Additionally, certain students? timesheets were not properly reviewed/approved.Cause:Insufficient internal controls and lack of administrative oversight with respect to disbursement of federal awards.Effect or Potential Effect:The University was not in compliance with FWS disbursement compliance requirements.Questioned Costs:Indeterminable.Context:? For 10 of 40 students selected for FWS testing, the amount of compensation disbursed to the student did not agree to the hours worked per the approved timesheet.? For 2 of 40 students selected for FWS testing, the students? timesheet was not properly reviewed/approved by a supervisor as required.Identification as a Repeat Finding:No similar findings noted in the prior year.Recommendation:We recommend the University enhance its policies, procedures and internal controls to ensure that students receiving FWS compensation are paid timely, and for the correct amounts. Additionally, we recommend that student timesheet be approved prior to the disbursement of funds.

Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48).Condition:The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. As a result, certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Additionally, the University?s procurement policy was not appropriately updated to reflect the new Procurements requirements in the Uniform Guidance.Cause:Insufficient internal controls and administrative oversight over Procurement requirements.Effect or Potential Effect:The University was not in compliance with Procurement compliance requirements.Questioned Costs:None.Context:For 8 of 14 procurement transactions selected for testing, the University was unable to provide adequate sole source or competitive bidding documentation.Identification as a Repeat Finding:This is a repeat finding from prior year. This was reported as finding 2020-013 in the prior year schedule of findings and questioned costs.Recommendation:We recommend that the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.

Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):F. Equipment and Real Property Management - Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every 2 years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.Condition:Certain federal funded equipment was not appropriately tagged to indicate Federal ownership. The University was also unable to provide documentation to support that all federally funded equipment property records included the required information.Cause:Insufficient internal controls and administrative oversight in regard to Equipment and Real Property Management requirements.Effect or Potential Effect:The University did not comply with the requirements of Equipment and Real Property Management.Questioned Costs:None.Context:For 3 of 9 equipment items selected for testing, University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership. Additionally, the University was unable to provide documentation to support that all federally funded equipment property records included the required information (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value.Identification as a Repeat Finding:This is a repeat finding from prior year. This was reported as finding 2020-014 in the prior year schedule of findings and questioned costs.Recommendation:We recommend that the University enhance its policies, procedures and internal controls over the applicable compliance requirements of the Equipment and Real Property Management to ensure that equipment and real property purchased with federal funds are appropriately maintained as required.

Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):N. Special Tests and Provisions (Publications) - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.Condition:The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing.Cause:Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.Effect or Potential Effect:The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.Questioned Costs:None.Context:We noted the following exceptions:? For 7 of 9 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility.Identification as a Repeat Finding:This is a repeat finding from prior year. This was reported as finding 2020-015 in the prior year schedule of findings and questioned costs.Recommendation:We recommend that the University properly enhance its policies, procedures and internal controls over the applicable Special Tests and Provisions requirements within its grant agreements.

Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):L. Reporting - 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. Institutions must report publicly ontheir primary websites on a quarterly basis for both student portion and institutional portion funds.Condition:The University did not appropriately prepare their quarterly reports during the year ended June 30, 2021. Additionally, quarterly reports were not posted to the University?s website timely.Cause:Insufficient internal controls and administrative oversight with respect to HEERF reporting requirements.Effect or Potential Effect:The University did not comply with the requirements of HEERF reporting.Questioned Costs:None.Context:The University did not prepare certain quarterly reports using the appropriate reporting form. Additionally, quarterly reports were not submitted within 10 days of each quarter end as required.Identification as a Repeat Finding:This is a repeat finding from prior year. This was reported as finding 2020-016 in the prior year schedule of findings and questioned costs.Recommendation:We recommend that the University enhance its policies, procedures and internal controls over the applicable HEERF reporting requirements.

Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):A. Activities Allowed or Unallowed - For the (a)(1) Student Aid Portion (Assistance Listing 84.425E), disbursements made under the Student Aid Portion are required to be made directly to students. ED?s final rule (Eligibility to Receive Emergency Financial Aid Grants to Students under the Higher Education Emergency Relief Programs, May 14, 2021) on student eligibility for HEERF states that all students who are or were enrolled in an institution of higher education on or after the date of the declaration of the national emergency due to the coronavirus (March 13, 2020) are eligible for emergency financial aid grants from the HEERF, regardless of whether they completed a FAFSA or are eligible for Title IV. Institutions may not (1) condition the receipt of emergency financial aid grants to students on continued or future enrollment in the institution, (2) use the emergency financial aid grants to satisfy a student?s outstanding account balance, unless it has obtained the student?s written (or electronic), affirmative consent, or (3) require such consent as a condition of receipt of or eligibility for the emergency financial aid grant.Condition:The University did not disburse HEERF Student Aid Portion funding directly to students as required. Additionally, the University did not obtain students? written (or electronic) affirmation consent prior to disbursing HEERF Student and Institutional funding to satisfy students? outstanding account balance.Cause:Insufficient internal controls and administrative oversight with respect to HEERF disbursement requirements.Effect or Potential Effect:The University did not comply with the requirements of HEERF Activities Allowed or Unallowed requirements.Questioned Costs:None.Context:The University applied HEERF emergency aid grants to student?s account and did not disburse HEERF Student Aid Portion funding directly to students as required. Additionally, the University did not obtain students? written (or electronic) affirmation consent prior to disbursing HEERF Student and Institutional funding to satisfy students? outstanding account balance.Identification as a Repeat Finding:No similar findings noted in the prior year.Recommendation:We recommend that the University enhance its policies, procedures and internal controls over the applicable HEERF disbursement requirements.

Federal Program Information: Student Financial Assistance Cluster (various CFDA #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting - The University is required to update students? statuses on the National Student Loans Data System (?NSLDS?) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University?s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: ? For 27 of 40 students sampled whose status changed during the fiscal year, the University failed to submit a timely notification to the NSLDS website. ? For 4 out of 40 students sampled whose status changed during the fiscal year, the University was unable to provide documentation that an accurate notification was submitted to the NSLDS website. ? For 7 of 12 months in the fiscal year, error records identified in Error/Acknowledgment files were not corrected within the required timeframe. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2019-008 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University properly follow its policies and procedures and enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe and error records are corrected and submitted timely.

Federal Direct Loans (CFDA# 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Disbursements To or On Behalf of Students - Award Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan, FPL funds, or TEACH Grants. Condition: For certain students who received disbursements of Federal Direct Loan funds, the University did not notify the student or parent of their award disbursement within the required time frame after crediting the student?s account. Cause: Insufficient internal controls and administrative oversight with respect to student aid award notifications Effect or Potential Effect: The University is not in compliance with award notification requirements. Questioned Costs: None. Context: ? For 2 of 40 students selected for testing who received Federal Direct PLUS Loan funds, the University did not properly notify the parent borrower as required. ? For 16 of 40 students selected for testing, the University was unable to provide documentation confirming that an award notification was sent and thus, we were unable to determine whether notifications were made within the required timeframe. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2019-011 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its internal controls over award notifications to ensure that such notifications are sent to students and/ or parents within the required timeframe.

Federal Program Information: Student Financial Assistance Cluster (various CFDA #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Return of Title IV Funds: The institution must provide within 30 days of the date of the institution?s determination that the student withdrew, a written notification to the student, or parent in the case of parent PLUS loan, that requests confirmation of any post-withdrawal disbursement of loan funds that the institution wishes to credit to the student?s account and/or that the student/parent can receive as a direct disbursement, identifying the type and amount of those loan funds and explaining that a student, or parent in the case of a parent PLUS loan, may accept or decline some or all of those funds (34 CFR 668.22(a)(5)(iii)(A)). The deadline to submit an origination or disbursement record under the Direct Loan Program is the earlier of (a) 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported disbursement data, except that records of disbursements made between October 1, 2017 and March 25, 2018, may be submitted no later than April 9, 2018; or (b) July 31, 2020 (83 FR 62563). Condition: The University did not send written notifications regarding certain students? post-withdrawal disbursements and/or adjust previously reported disbursement data within the required timeframe. Cause: Insufficient administrative oversight with respect to return of Title IV funds requirements. Effect or Potential Effect: The University was not compliant with the Return of Title IV Funds compliance requirements. Questioned Costs: None. Context: ? For 1 of 25 students selected for refund calculation testing, written notification providing the student the opportunity to accept all or part of a post-withdrawal disbursement of Title IV loan funds was not sent within the required timeframe. ? For 2 of 25 students selected for refund calculation testing, the required refund was not adjusted within the COD system within the required timeframe. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2019-009 and 2019-012 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University enhance its process surrounding the disbursement of federal student aid to ensure compliance with the return of Title IV Funds requirements.

Federal Program Information: Federal Direct Loans (CFDA# 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility ? Aggregate Loan Limits for Subsidized and Unsubsidized Loans: Aggregate loan limits for subsidized and unsubsidized loans are: $31,000 for a dependent undergraduate student (except for dependent students whose parents cannot borrow a PLUS loan) (subsidized loan portion may not exceed $23,000 of the aggregate limit amount); $57,500 for an independent student and for a dependent student whose parents cannot borrow a PLUS loan (subsidized loan portion may not exceed $23,000 of the aggregate limit amount); and $138,500 for a graduate or professional student (subsidized portion limited to $65,500). This $138,500 limit includes loans for undergraduate study. Condition: A student was disbursed Federal Direct Loan funds in excess of the aggregate Subsidized and Unsubsidized direct loan limit. Cause: Lack of administrative oversight over the packaging of Federal Direct Loans. Effect or Potential Effect: The University is not in compliance with packaging direct loan within aggregate loan limits. Questioned Costs: Below reporting threshold. Context: For 1 of 25 students selected for testing, the student was packaged and disbursed Federal Direct Loans in excess of the aggregate loan limit. Identification as a Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend that the University enhance its procedures to ensure that it Federal Direct Loans are awarded/disbursed in accordance with federal guidelines.

Federal Program Information: Student Financial Assistance Cluster (CFDA#: various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting ? Fiscal Operations Report and Application to Participate (?FISAP?) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP. Condition: The University submitted the 2019-2020 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures. Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame. Effect: The University is not in compliance with special reporting requirements. Questioned Costs: None. Context: The University submitted the annual FISAP for the 2019-2020 reporting year by the required deadline, however subsequently errors were identified within the report. As of the date of our Single Audit report, these errors remain uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain amounts reported within the submitted FISAP, and we were therefore unable to perform testing of certain key line items for the 2019-2020 year. Identification as a Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.

Federal Program Information: Federal Direct Loans (CFDA# 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution?s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student?s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the ?ED?) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution?s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame and/or allowable thresholds. Cause: Lack of administrative oversight regarding Cash Management compliance requirements. Effect or Potential Effect: The University should continue to enhance its policies and procedures in place to ensure that compliance is maintained with respect to the Cash Management. As a result, certain funds were overdrawn or held in excess of the allowable time frame and/or allowable thresholds. Questioned Costs: None. Context: 2 instances of funds drawn and held in excess of the allowable time frame and/or thresholds were identified throughout the University?s fiscal year. Identification as a Repeat Finding: No similar findings identified in the prior year. Recommendation: While improvements have been made, we recommend that the University continue to enhance its internal controls to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to the U.S. Department of Education

Federal Program Information: Research and Development Cluster (various CFDA #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. As a result, certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Additionally, the University?s procurement policy was not appropriately updated to reflect the new Procurements requirements in the Uniform Guidance. Cause: Insufficient internal controls and lack of effective administrative oversight over Procurement requirements. Effect or Potential Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: The University did not have formal policies and procedures in place during the fiscal year to ensure compliance with the Procurement requirements included in the Uniform Guidance, resulting in 2 of 8 procurement transactions selected for testing not having adequate sole source or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2019-015 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.

Federal Program Information: Research and Development Cluster (various CFDA #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every 2 years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: While a physical inventory of equipment was performed for the year ended June 30, 2020, the University was unable to provide documentation to support that all federally funded equipment included in their inventory procedures. Cause: Insufficient internal controls and administrative oversight in regard to Equipment and Real Property Management requirements. Effect or Potential Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: For 6 of 7 equipment items selected for testing, the equipment was not included in the inventory report provided. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2019-016 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University enhance its policies, procedures and internal controls over the applicable compliance requirements of the Equipment and Real Property Management to ensure that equipment and real property purchased with federal funds are appropriately maintained and that a physical inventory is performed every 2 years as required.

Federal Program Information: Research and Development Cluster (various CFDA #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions (Publications) - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors. Condition: The University did not properly include the appropriate acknowledgement of support and a disclaimer of responsibility in certain publications selected for testing. Cause: Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements. Effect or Potential Effect: The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support. Questioned Costs: None. Context: We noted the following exceptions: ? For 7 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate acknowledgement of support and/or disclaimer of responsibility. Identification as a Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend that the University properly follow its policies, procedures and internal controls over the applicable Special Tests and Provisions requirements within its grant agreements.

Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (CFDA 84.425E) and Institutional Portion (CFDA 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - Auditors should determine if an institution was both timely and accurate in posting in publicly posting its Quarterly Reporting Form from October 30, 2020, onward and sample these quarterly public reports and reconcile the publicly reported amounts with underlying documentation to ensure accuracy. Auditors should examine the annual report and reconcile that reported amounts with underlying documentation and the public quarterly reporting amounts to ensure accuracy. Condition: The University did not prepare or disclose a quarterly report for the 1st quarter due October 30, 2020. Data included within the annual report provided by the University did not reconcile with underlying documentation. Cause: Insufficient administrative oversight with respect to HEERF reporting requirements. Effect or Potential Effect: The University did not comply with the requirements of HEERF reporting. Questioned Costs: None. Context: We noted the following exceptions: ? For 1 of 2 quarterly reports selected, the University did not post required data on its website for public disclosure. Identification as a Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend that the University properly follow its policies and procedures over the applicable HEERF reporting requirements.

Federal Program Information: Federal Direct Loans (CFDA #84.268); Federal Pell Grant Program (CFDA #84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Borrower Data Transmission and Reconciliation - Direct Loans - Federal regulations (34 CFR 690.83 and 685.301) require that the University submit Common Origination and Disbursement (?COD?) information for students in an accurate and timely manner (no earlier than 7 days before and no later than 15 days after disbursement of funds). Condition: For certain students identified through our testing, the University did not submit Federal Direct Student Loans payment data through the COD website within the required timeframes. Cause: Insufficient internal controls and administrative oversight resulted in the untimely reporting of certain Federal Direct Loans and Federal Pell Grant Program payment data. Effect or Potential Effect: The University is not in compliance with COD reporting requirements. Failure to submit and update COD records in a timely manner could result in improper awards of Title IV funds. Questioned Costs: None. Context: ? For 15 of 40 students selected for disbursement testing, the University did not report the Federal Direct Loan disbursements to COD within the required time frame. ? For 1 of 40 students selected for disbursement testing the University was unable to provide documentation to support that a valid master promissory note was received prior to the disbursement of funds. ? For 19 of 40 students selected for disbursement testing, the University did not report the Federal Pell Grant disbursements to COD within the required time frame. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2018-012 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its internal controls to ensure that disbursement dates are entered into the COD website no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations.

Federal Program Information: Student Financial Assistance Cluster (various CFDA #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting - The University is required to update students? statuses on the National Student Loans Data System (?NSLDS?) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University?s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: ? For 18 of 40 students sampled whose status changed during the fiscal year, the University failed to submit a timely notification to the NSLDS website. ? For 14 out of 40 students sampled whose status changed during the fiscal year, the University was unable to provide documentation that an accurate notification was submitted to the NSLDS website. ? For 9 of 12 months in the fiscal year, error records identified in Error/Acknowledgment files were not corrected within the required timeframe. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2018-013 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University properly follow its policies and procedures and enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe and error records are corrected and submitted timely.

Federal Program Information: Student Financial Assistance Cluster (CFDA#: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date the school issued the check. Condition: The University did not refund credit balances to certain students within the required timeframe. Cause: Lack of administrative oversight with respect to the disbursement of federal awards. Effect: The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance. Questioned Costs: None. Context: For 3 of 40 students selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14 day timeframe. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2018-017 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University enhance its policies and procedures by implementing a process to disburse credit balances created by federal awards within the required time frame.

Federal Program Information: Federal Work Study Program (CFDA# 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students - General Disbursement Criteria ? Federal Work-Study Program ? Per the Federal Student Aid Handbook, A student?s need places a limit on the total FWS earnings permissible but has no bearing on his or her wage rate. It is not acceptable to base the wage rate on need or on any other factor not related to the student?s skills or job description. However, in most cases, students performing jobs comparable to those of other employees should be paid comparable wages, whether the other employees are students at different class levels or are regular employees. Condition: For certain students identified through our testing, the University paid FWS compensation pay rates that exceeded required limits. Cause: Insufficient internal controls and administrative oversight with respect to disbursement of federal awards. Effect: The University was not in compliance with FWS disbursement compliance requirements. Questioned Costs: Indeterminable. Context: 6 of 22 students tested were paid FWS compensation pay rates that exceeded required limits. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University follow its policies and procedures and enhance its internal controls to ensure that students receiving FWS compensation are paid wage rates that do not exceed required limits.

Federal Program Information: Federal Direct Loans (CFDA# 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Disbursements To or On Behalf of Students - Award Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan, FPL funds, or TEACH Grants. Condition: For certain students who received disbursements of Federal Direct Loan funds, the University did not notify the student or parent of their award disbursement within the required time frame after crediting the student?s account. Cause: Insufficient internal controls and administrative oversight with respect to student aid award notifications Effect: The University is not in compliance with award notification requirements. Questioned Costs: None. Context: ? For 6 of 40 students selected for testing who received Federal Direct PLUS Loan funds, the University did not properly notify the parent borrower as required. ? For 40 of 40 students selected for testing, the University was unable to provide documentation confirming that an award notification was sent and thus, we were unable to determine whether notifications were made within the required timeframe. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2018-019 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its internal controls over award notifications to ensure that such notifications are sent to students and/ or parents within the required timeframe.

Federal Program Information: Student Financial Assistance Cluster (various CFDA #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Return of Title IV Funds: The institution must provide within 30 days of the date of the institution?s determination that the student withdrew, a written notification to the student, or parent in the case of parent PLUS loan, that requests confirmation of any post-withdrawal disbursement of loan funds that the institution wishes to credit to the student?s account and/or that the student/parent can receive as a direct disbursement, identifying the type and amount of those loan funds and explaining that a student, or parent in the case of a parent PLUS loan, may accept or decline some or all of those funds (34 CFR 668.22(a)(5)(iii)(A)). The deadline to submit an origination or disbursement record under the Direct Loan Program is the earlier of (a) 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported disbursement data, except that records of disbursements made between October 1, 2017 and March 25, 2018, may be submitted no later than April 9, 2018; or (b) July 31, 2020 (83 FR 62563). Condition: The University did not send written notifications regarding certain students? post-withdrawal disbursements and/or adjust previously reported disbursement data within the required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to return of Title IV funds requirements. Effect: The University was not compliant with the Return of Title IV Funds compliance requirements. Questioned Costs: None. Context: For 2 of 15 students selected for refund calculation testing, written notification providing the student the opportunity to accept all or part of a post-withdrawal disbursement of Title IV loan funds was not sent within the required timeframe. For 9 of 15 students selected for refund calculation testing, the required refund was not adjusted within the COD system within the required timeframe. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2018-014 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University enhance its internal controls surrounding the disbursement of federal student aid to ensure compliance with the return of Title IV Funds requirements.

Federal Program Information: Federal Work Study Program (CFDA# 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): G. Earmarking ? Federal Work Study - An institution must use at least seven percent of the sum of its initial and supplemental FWS allocations for an award year to compensate students employed in community service activities unless waived by the Secretary of Education (34 CFR section 675.18). Condition: The University was unable to provide documentation to support that the seven percent FWS earmarking requirement was met for the year. Cause: Insufficient internal controls and administrative oversight with respect to FWS earmarking requirements. Effect: The University was not in compliance with FWS earmarking compliance requirements. Questioned Costs: None. Context: The University was unable to provide documentation to support that the seven percent FWS earmarking requirement was met for the year. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University follow its policies and procedures and enhance its internal controls to ensure that the FWS earmarking requirement is met and that documentation supporting such requirements is maintained for adequate period of time.

Federal Program Information: Federal Supplemental Educational Opportunity Grant (?FSEOG?) (CFDA#: 84.007) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility - In selecting among eligible students for FSEOG awards in each award year, an institution shall select those students with the lowest expected family contribution who will also receive Federal Pell Grants in that year (34 CFR 676.10). Condition: The University did not give priority to Federal Pell recipients when disbursing FSEOG funds. Cause: Lack of administrative oversight over the disbursement of FSEOG funds. Effect: The University is not in compliance with required federal guidelines. Questioned Costs: Below reporting threshold. Context: Of the total population of students awarded FSEOG funds during the year, 5 students were given priority over Federal Pell Grant recipients. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2018-016 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University enhance its procedures to ensure that it disburses FSEOG funds to those students with the lowest expected family contribution who will also receive Federal Pell Grants in that year.

Federal Program Information: Research and Development Cluster (various CFDA #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 ? 215.48). Condition: The University?s purchasing policy and procedures are not being appropriately followed in all cases with respect to the procurement of goods and services funded by federal awards. As a result, certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process. Additionally, the University?s procurement policy was not approximately updated to reflect the new Procurements requirements in the Uniform Guidance. Cause: Insufficient internal controls and lack of effective administrative oversight over Procurement requirements. Effect: The University was not in compliance with Procurement compliance requirements. Questioned Costs: None. Context: The University did not have formal policies and procedures in place during the fiscal year to ensure compliance with the Procurement requirements included in the Uniform Guidance, resulting in 4 of 8 procurement transactions selected for testing not having adequate sole source or competitive bidding documentation. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2018-021 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations

Federal Program Information: Research and Development Cluster (various CFDA #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every 2 years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: The University was unable to provide documentation to support that a physical inventory of federally funded equipment was performed during the year ended June 30, 2019. Cause: Lack of administrative oversight in regard to Equipment and Real Property Management requirements. Effect: The University did not comply with the requirements of Equipment and Real Property Management. Questioned Costs: None. Context: The University was unable to provide documentation to support that a physical inventory of federally funded equipment was performed every 2 years as required. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its policies and procedures over the applicable compliance requirements of the Equipment and Real Property Management to ensure that equipment and real property purchased with federal funds are appropriately maintained and that a physical inventory is performed every 2 years as required.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION