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High Point UniversityNon-Profit

EIN: 560529999

UEI: Z2AEQJNCQPK6

Audited by: Smith Leonard, PLLC

Cognizant agency: 84 [Department of Education]

View federal awards & risk assessment →

Data as of August 31, 2026

High Point University10 audit years20 findings12 repeat
10
Audit Years
20
Total Findings
12
Repeat Findings
$96.9M
Federal Awards Expended (FY 2025)

FY 2025-05-31

LOW-RISK AUDITEE$96,917,967 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on February 27, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 27, 2026 (6 days ago).

What is a management decision? →
2025-001
Cash Management
REPEAT OF 2024-001OTHER MATTERS

Information on Federal Program ‒ Federal Family Education Loans (Assistance Listing Number 84.032) Criteria – Compliance Requirement C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. Condition – During the audit, we noted the following:  The University has approximately $388,000 of excess cash held in a segregated federal funds cash account, which relates to awards from prior years. Cause – Prior management’s lack of oversight of student financial aid in prior years. The lack of proper oversight and insufficient internal controls resulted in excess cash received from third-party awarding agencies, which was not properly refunded, causing the University to have excess cash on hand. Effect – The University has excess cash on hand and was not in compliance with cash management requirements; however, the University has the funds properly held in an identifiable federal funds cash account, as they are currently investigating the best way to refund the excess cash. Questioned Costs – None. Context – We reviewed cash received and expended in a prior year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year. The University reconciled the remaining amounts and discovered the transactions the excess cash relates to. The University is working with the Government to send the funds back, however, at year end they have not been returned. Indication of a Repeat Finding – This is a repeat finding 2024-001 from prior year. Recommendation – We recommend the University enhance internal controls over compliance with cash management requirements, as well as work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand. Views of Responsible Officials – See corrective action plan.

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Full finding narrative

Information on Federal Program ‒ Federal Family Education Loans (Assistance Listing Number 84.032) Criteria – Compliance Requirement C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. Condition – During the audit, we noted the following:  The University has approximately $388,000 of excess cash held in a segregated federal funds cash account, which relates to awards from prior years. Cause – Prior management’s lack of oversight of student financial aid in prior years. The lack of proper oversight and insufficient internal controls resulted in excess cash received from third-party awarding agencies, which was not properly refunded, causing the University to have excess cash on hand. Effect – The University has excess cash on hand and was not in compliance with cash management requirements; however, the University has the funds properly held in an identifiable federal funds cash account, as they are currently investigating the best way to refund the excess cash. Questioned Costs – None. Context – We reviewed cash received and expended in a prior year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year. The University reconciled the remaining amounts and discovered the transactions the excess cash relates to. The University is working with the Government to send the funds back, however, at year end they have not been returned. Indication of a Repeat Finding – This is a repeat finding 2024-001 from prior year. Recommendation – We recommend the University enhance internal controls over compliance with cash management requirements, as well as work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand. Views of Responsible Officials – See corrective action plan.

Corrective Action Plan

Finding 2025-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. University’s Response: The excess cash balance relates to prior award years and is not part of the currently audited period. The University has maintained these funds in a segregated federal funds account and safeguarded them from expenditure while performing reconciliation. The University is actively coordinating with the Department of Education to determine the appropriate process for returning the excess cash and will follow their guidance once received. The University has continued to ensure these funds are not comingled and has protected them from spending. Because of the discrepancies identified, each student’s loan history had to be reviewed and compared between the University Information System, the lender rosters, and the National Student Loan Database System (NSLDS) records. This individual review and reconciliation have proven to be a tedious but necessary process to identify the funds never posted to student records, returned to lenders, or entered incorrectly in the three separate systems of record. Corrective Action Plan: The University, working with an external financial aid consulting firm with experience in reconciling FFEL loan programs, has finished researching all related accounts against the National Student Loan Database System (NSLDS) records. The University continues to work with the Department of Education to determine how to return funds in instances where the last lender used is no longer available to process student loan funds, and lastly, book the appropriate entries for any funds determined to belong to the University that were not moved to the University operating accounts properly at the time of the transactions. Name of the responsible person: Brad Calloway, Senior Vice President for Business Affairs Anticipated completion date: Unknown

Prior Finding References

2024-001

About Cash Management →
2025-002
Special Tests & Provisions
REPEAT OF 2024-002QUESTIONED COSTSOTHER MATTERS

Information on Federal Program ‒ Federal Work-Study Program (Assistance Listing Number 84.033) Criteria – Compliance Requirement N – Special Tests and Provisions – Institutions are required to verify all amounts paid are appropriately earned. Condition – During our testing of the Federal Work-Study program, we noted the following:  For 2 students out of a population of 229 students who received Federal Work-Study, the University was unable to verify time punches, which resulted in overpayments of Federal Work-Study aid; however, the University was able to prove there were offsetting hours that were subsequently claimed as allowable hours, therefore, a return of funds is not needed. Cause – 2 students whose time entered and paid were not able to be verified. Effect – The students and the University were not in compliance with the Federal Work-Study program guidelines. Questioned Costs – $508 Context – As noted in the condition, 2 exceptions out of a population of 229 students were found, which resulted in the students and the University not being in compliance with the program rules. Indication of a Repeat Finding – This is a repeat finding 2024-002 from prior year. Recommendation – We recommend the University ensure its internal controls, policies and procedures are followed on a consistent basis regarding the Federal Work-Study Program. Views of Responsible Officials – See corrective action plan.

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Full finding narrative

Information on Federal Program ‒ Federal Work-Study Program (Assistance Listing Number 84.033) Criteria – Compliance Requirement N – Special Tests and Provisions – Institutions are required to verify all amounts paid are appropriately earned. Condition – During our testing of the Federal Work-Study program, we noted the following:  For 2 students out of a population of 229 students who received Federal Work-Study, the University was unable to verify time punches, which resulted in overpayments of Federal Work-Study aid; however, the University was able to prove there were offsetting hours that were subsequently claimed as allowable hours, therefore, a return of funds is not needed. Cause – 2 students whose time entered and paid were not able to be verified. Effect – The students and the University were not in compliance with the Federal Work-Study program guidelines. Questioned Costs – $508 Context – As noted in the condition, 2 exceptions out of a population of 229 students were found, which resulted in the students and the University not being in compliance with the program rules. Indication of a Repeat Finding – This is a repeat finding 2024-002 from prior year. Recommendation – We recommend the University ensure its internal controls, policies and procedures are followed on a consistent basis regarding the Federal Work-Study Program. Views of Responsible Officials – See corrective action plan.

Corrective Action Plan

Finding 2025-002 Program: Federal Work Study Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify all amounts paid are appropriately earned. University’s Response: The University uses Workday HCM as the official system of record for student employee time reporting. Student workers record time directly in Workday, and supervisors review and approve time entries each pay period prior to payroll processing. The time punches in question were reviewed and approved in Workday in accordance with standard procedures at the time of payment. Because the audit occurred six to eighteen months after the work was performed by the students, supervisors were unable to independently recall specific hours worked beyond the documentation maintained in Workday. However, system records indicate that the hours were reviewed and approved, and the University confirmed that any questioned amounts were offset by subsequent allowable hours worked. As noted by the auditors, questioned costs of $508 were identified; however, no return of Federal Work‑Study funds was required based on allowable offsetting hours. Corrective Action Plan: The University will continue to rely on its existing Federal Work‑Study timekeeping and payroll procedures, which require that student wages be based on hours worked in allowable positions. Management believes the condition identified was isolated in nature and not indicative of a systemic issue within the Federal Work‑Study program. No additional corrective action is planned at this time. Existing procedures remain in effect. Repeat Finding Explanation This finding is reported as a repeat due to similar conditions noted in the prior year related to Federal Work‑Study payroll documentation. However, the current‑year finding reflects a reduced scope, a lower number of students, and a significantly reduced questioned cost amount compared to the prior year. Management believes the issue is not systemic. Name of the responsible person: Marc Sears, Vice President of Human Resources; Brad Calloway, Senior Vice President for Business Affairs; Sandra Fantauzzi, Student Employment Program Manager; Megan Inch, Associate Vice President of Student Financial Planning

Prior Finding References

2024-002

About Special Tests and Provisions →
2025-003
Other
OTHER MATTERS

Information on Federal Program ‒ Grants to States for Medicaid (Assistance Listing Number 93.778) Criteria – Consistent with the requirements of 2 CFR 200.514, Subpart 3, L Reporting and consistent with the requirements of the subaward agreement, the University is required to submit compliance reporting to the grantor annually beginning in the year the funds were received. Condition – During our testing of this grant, we noted the following:  The University did not submit the compliance reporting required under the subaward agreement. The grantor never provided the appropriate report templates so the University was unable to submit the necessary documentation. Cause – Management oversight and insufficient internal controls over grant compliance and lack of support from the grantor. Effect – The University was not in reporting compliance with subaward agreement, however, the funds were appropriately utilized within parameters of the grant agreement. Questioned Costs – None Context – The University never received the templates required for reporting and the grantor never requested the University submit the reporting. The University used the funds in compliance with the agreement but did not follow the full length of reporting requirements. Indication of a Repeat Finding – This is a new finding in 2025. Recommendation – We recommend the University ensure its internal controls, policies, and procedures are followed on a consistent basis regarding post award grant compliance and reporting. Views of Responsible Officials – See corrective action plan.

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Full finding narrative

Information on Federal Program ‒ Grants to States for Medicaid (Assistance Listing Number 93.778) Criteria – Consistent with the requirements of 2 CFR 200.514, Subpart 3, L Reporting and consistent with the requirements of the subaward agreement, the University is required to submit compliance reporting to the grantor annually beginning in the year the funds were received. Condition – During our testing of this grant, we noted the following:  The University did not submit the compliance reporting required under the subaward agreement. The grantor never provided the appropriate report templates so the University was unable to submit the necessary documentation. Cause – Management oversight and insufficient internal controls over grant compliance and lack of support from the grantor. Effect – The University was not in reporting compliance with subaward agreement, however, the funds were appropriately utilized within parameters of the grant agreement. Questioned Costs – None Context – The University never received the templates required for reporting and the grantor never requested the University submit the reporting. The University used the funds in compliance with the agreement but did not follow the full length of reporting requirements. Indication of a Repeat Finding – This is a new finding in 2025. Recommendation – We recommend the University ensure its internal controls, policies, and procedures are followed on a consistent basis regarding post award grant compliance and reporting. Views of Responsible Officials – See corrective action plan.

Corrective Action Plan

Finding 2025-003 Program: Grants to States for Medicaid Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of the subaward agreement, the University is required to submit compliance reporting to the grantor annually beginning in the year the funds were received. University’s Response: The University was not provided with the required compliance reporting templates at the time the subaward was issued. As a result, the University was unable to submit the required reports during the applicable reporting period. The grantor did not request submission of the reports during this time. Upon becoming aware of the reporting requirement during the Single Audit process, the University requested the appropriate templates and reporting guidance from the grantor. The templates were subsequently provided, and the University is continuing to work with the grantor to ensure accurate completion and submission of the required compliance reporting. The University confirms that grant funds were used in accordance with the terms and allowable activities of the subaward agreement. Corrective Action Plan: The University will continue to seek clarification and guidance from the grantor regarding required compliance reporting and the appropriate format for submission. If sufficient guidance is not provided, the University will submit the required compliance reporting to the best of its ability based on available information, understanding that the submission may be subject to review or revision by the grantor. No additional corrective action is planned at this time. The University will continue to work with the grantor to address reporting requirements as information becomes available. Name of the responsible person: Brian Shollenberger, Vice President for Financial Affairs and University Development Anticipated completion date: May 31, 2026

About Other →
2025-004
Other
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

Information on Federal Program ‒ SFA Cluster Criteria – Consistent with the requirements of 2 CFR Part 668, Subpart B, Part 16, the University is required to identify and resolve discrepancies in the information received from different sources with respect to each student’s financial aid. Condition – The University discovered and disclosed to us:  3 students from a total population of 3,115 students who received financial aid, the University did not address issues with the students FASFA before distributing funds totaling $160,789. The University refunded the unresolved differences to the Department of Education totaling $160,789 subsequent to the award disbursement.  One of the 3 students was also improperly awarded aid in 2023-2024. The student was not eligible for aid, so the University has to return $31,571. The refund has not been processed and is still owed to the Department of Education at the time of report issuance. Cause – Management oversight and insufficient internal controls in the awarding process, resulting in 3 students being improperly awarded aid. Effect – The University was not in compliance with awarding procedures and the University refunded $160,789 to the Department of Education and still owes $31,571. Questioned Costs – $192,360 Context – The University’s system was not updated for ISIR C flags. The system and internal review did not identify the issues before aid was disbursed to student accounts. Indication of a Repeat Finding – This is a new finding in 2025. Recommendation – We recommend the University ensure its internal controls, policies, and procedures are followed on a consistent basis regarding the awarding process. Views of Responsible Officials – See corrective action plan.

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Full finding narrative

Information on Federal Program ‒ SFA Cluster Criteria – Consistent with the requirements of 2 CFR Part 668, Subpart B, Part 16, the University is required to identify and resolve discrepancies in the information received from different sources with respect to each student’s financial aid. Condition – The University discovered and disclosed to us:  3 students from a total population of 3,115 students who received financial aid, the University did not address issues with the students FASFA before distributing funds totaling $160,789. The University refunded the unresolved differences to the Department of Education totaling $160,789 subsequent to the award disbursement.  One of the 3 students was also improperly awarded aid in 2023-2024. The student was not eligible for aid, so the University has to return $31,571. The refund has not been processed and is still owed to the Department of Education at the time of report issuance. Cause – Management oversight and insufficient internal controls in the awarding process, resulting in 3 students being improperly awarded aid. Effect – The University was not in compliance with awarding procedures and the University refunded $160,789 to the Department of Education and still owes $31,571. Questioned Costs – $192,360 Context – The University’s system was not updated for ISIR C flags. The system and internal review did not identify the issues before aid was disbursed to student accounts. Indication of a Repeat Finding – This is a new finding in 2025. Recommendation – We recommend the University ensure its internal controls, policies, and procedures are followed on a consistent basis regarding the awarding process. Views of Responsible Officials – See corrective action plan.

Corrective Action Plan

Finding 2025-004 Program: SFA Cluster Assistance Listing No.: Various Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of 2 CFR Part 668, Subpart B, Part 16, the University is required to identify and resolve discrepancies in the information received from different sources with respect to each student’s financial aid. University’s Response: The University identified that certain ISIR comment codes (including ISIR “C” flags) were not properly mapped within the student information system. As a result, those comment codes were not displayed or identified for review within the system workflow. At the time financial aid was disbursed, there were no unresolved C‑flags visible in the system requiring resolution prior to disbursement. The University self‑identified this system configuration issue and disclosed it to its auditors. Upon identification, the ISIR comment code mapping was corrected, and the University performed a review of affected records to ensure all required eligibility issues were identified and resolved. As a result of this issue, financial aid was disbursed to three students who were later determined to require additional eligibility review. The University refunded $160,789 to the Department of Education related to these students. Additionally, one student was determined to have been ineligible for aid in a prior award year, resulting in an additional refund obligation of $31,571, which remains payable to the Department of Education at the time of report issuance. Corrective Action Plan: The ISIR comment code mapping issue has been corrected, and all identified affected records have been reviewed and resolved. Management believes the condition resulted from a specific system configuration issue and was isolated in nature. No additional corrective action is planned at this time. The University believes the corrective actions already taken have addressed the root cause of the issue and that existing processes are operating as intended. Name of the responsible person: Megan Inch, Associate Vice President of Student Financial Planning; Brad Calloway, Senior Vice President for Business Affairs Anticipated completion date: Resolved

About Other →
2025-005
Other
QUESTIONED COSTSOTHER MATTERS

Information on Federal Program ‒ SFA Cluster Criteria – Consistent with the requirements of 2 CFR Part 200, Subpart F, Part 3, the auditor is required to test internal controls related to major programs. The specific procedures to test internal control on a caseby- case basis considering factors such as the non-federal entity’s internal controls, the compliance requirements, the audit objectives for compliance, the auditor’s assessment of control risk, and the audit requirement to test internal controls. Condition – During our Controls testing of University awarding and billing procedures, we noted the following:  For 5 students out of 40 sampled, from a population of 3,115 students who received financial aid, the University incorrectly calculated the Cost of Attendance (COA). As a result of the incorrect COA, 1 student was overawarded for classes during the summer semester. The University refunded the Department of Education $400 due to the overaward. Cause – Management oversight and insufficient internal controls in the awarding procedures, resulting in 1 student being overawarded. Effect – The University was not in compliance with refund requirements as the University owes the Department of Education a refund for the overawarded amount. Questioned Costs – $400 Context – For 5 students out of 40 sampled, the University’s system overawarded based on an incorrect cost of attendance being used within the students awarding calculation. Indication of a Repeat Finding – This is a new finding in 2025. Recommendation – We recommend the University ensure its internal controls, policies, and procedures are followed on a consistent basis regarding the awarding of federal aid. Views of Responsible Officials – See corrective action plan.

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Full finding narrative

Information on Federal Program ‒ SFA Cluster Criteria – Consistent with the requirements of 2 CFR Part 200, Subpart F, Part 3, the auditor is required to test internal controls related to major programs. The specific procedures to test internal control on a caseby- case basis considering factors such as the non-federal entity’s internal controls, the compliance requirements, the audit objectives for compliance, the auditor’s assessment of control risk, and the audit requirement to test internal controls. Condition – During our Controls testing of University awarding and billing procedures, we noted the following:  For 5 students out of 40 sampled, from a population of 3,115 students who received financial aid, the University incorrectly calculated the Cost of Attendance (COA). As a result of the incorrect COA, 1 student was overawarded for classes during the summer semester. The University refunded the Department of Education $400 due to the overaward. Cause – Management oversight and insufficient internal controls in the awarding procedures, resulting in 1 student being overawarded. Effect – The University was not in compliance with refund requirements as the University owes the Department of Education a refund for the overawarded amount. Questioned Costs – $400 Context – For 5 students out of 40 sampled, the University’s system overawarded based on an incorrect cost of attendance being used within the students awarding calculation. Indication of a Repeat Finding – This is a new finding in 2025. Recommendation – We recommend the University ensure its internal controls, policies, and procedures are followed on a consistent basis regarding the awarding of federal aid. Views of Responsible Officials – See corrective action plan.

Corrective Action Plan

Finding 2025-005 Program: SFA Cluster Assistance Listing No.: Various Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of 2 CFR Part 200, Subpart F, Part 3, the auditor is required to test internal controls related to major programs. The specific procedures to test internal control on a caseby-case basis considering factors such as the non-federal entity’s internal controls, the compliance requirements, the audit objectives for compliance, the auditor’s assessment of control risk, and the audit requirement to test internal controls. University’s Response: University management recognizes the finding and has addressed the issue. The Cost of Attendance calculation error affected a single student and resulted in an overaward of $400, which has been corrected and refunded to the Department of Education. Management believes the issue was isolated in nature and does not indicate a systemic weakness in the University’s awarding or billing processes. Corrective Action Plan The University reviewed the circumstances related to this finding and determined that the Cost of Attendance (COA) calculation error was limited in scope and affected a single student. The overaward of $400 has been corrected, and the required refund has been processed to the Department of Education. Management believes the condition was isolated in nature and does not indicate a systemic issue within the University’s awarding or billing processes. The University will continue to rely on its existing awarding and billing procedures, which are designed to support compliance with federal financial aid requirements. No additional corrective action is planned at this time. Existing procedures remain in effect. Name of the responsible person: Megan Inch, Associate Vice President of Student Financial Planning; Brad Calloway, Senior Vice President for Business Affairs Anticipated completion date: Resolved

About Other →

FY 2024-05-31

LOW-RISK AUDITEE$82,308,458 federal awards expended

FAC accepted this audit on February 28, 2025 — management decision was due August 28, 2025.

2024-001
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003

Information on Federal Program ‒ Federal Family Education Loans (Assistance Listing Number 84.032) Criteria – Compliance Requirement C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. Condition – During the audit, we noted the following:  The University has approximately $388,000 of excess cash held in a segregated federal funds cash account, which relates to awards from prior years. Cause – Prior management’s lack of oversight of student financial aid in prior years. The lack of proper oversight and insufficient internal controls resulted in excess cash received from third-party awarding agencies, which was not properly refunded, causing the University to have excess cash on hand. Effect – The University has excess cash on hand and was not in compliance with cash management requirements; however, the University has the funds properly held in an identifiable federal funds cash account, as they are currently investigating the best way to refund the excess cash. Questioned Costs – None. Context – We reviewed cash received and expended in a prior year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year. The University reconciled the remaining amounts and discovered the transactions the excess cash relates to. The University is working with the Government to send the funds back however at year end they have not been returned. Indication of a Repeat Finding – This is a repeat finding 2023-003 from prior year. Recommendation – We recommend the University enhance internal controls over compliance with cash management requirements, as well as work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand. Views of Responsible Officials – The cash balance of federal financial aid funds does not pertain to the currently audited year. The University is diligently ensuring that these funds continue to remain separate while undergoing reconciliation and has safeguarded them from expenditure. Given the complexity of reviewing each student’s history, we’ve enlisted the expertise of an external financial aid consulting firm experienced in reconciling FFEL loan programs.

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Full finding narrative

Information on Federal Program ‒ Federal Family Education Loans (Assistance Listing Number 84.032) Criteria – Compliance Requirement C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. Condition – During the audit, we noted the following:  The University has approximately $388,000 of excess cash held in a segregated federal funds cash account, which relates to awards from prior years. Cause – Prior management’s lack of oversight of student financial aid in prior years. The lack of proper oversight and insufficient internal controls resulted in excess cash received from third-party awarding agencies, which was not properly refunded, causing the University to have excess cash on hand. Effect – The University has excess cash on hand and was not in compliance with cash management requirements; however, the University has the funds properly held in an identifiable federal funds cash account, as they are currently investigating the best way to refund the excess cash. Questioned Costs – None. Context – We reviewed cash received and expended in a prior year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year. The University reconciled the remaining amounts and discovered the transactions the excess cash relates to. The University is working with the Government to send the funds back however at year end they have not been returned. Indication of a Repeat Finding – This is a repeat finding 2023-003 from prior year. Recommendation – We recommend the University enhance internal controls over compliance with cash management requirements, as well as work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand. Views of Responsible Officials – The cash balance of federal financial aid funds does not pertain to the currently audited year. The University is diligently ensuring that these funds continue to remain separate while undergoing reconciliation and has safeguarded them from expenditure. Given the complexity of reviewing each student’s history, we’ve enlisted the expertise of an external financial aid consulting firm experienced in reconciling FFEL loan programs.

Corrective Action Plan

Finding 2024-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. University’s Response: The University has continued to ensure these funds are not comingled and has protected them from spending. Because of the discrepancies identified, each student’s loan history had to be reviewed and compared between the University Information System, the lender rosters, and the National Student Loan Database System (NSLDS) records. This individual review and reconciliation have proven to be a tedious but necessary process to identify the funds never posted to student records, returned to lenders, or entered incorrectly in the three separate systems of record. Corrective Action Plan: The University, working with an external financial aid consulting firm with experience in reconciling FFEL loan programs, has finished researching all related accounts against the National Student Loan Database System (NSLDS) records. Our next steps include consolidating student returns to each of the different lenders, working with the Department of Education to determine how to return funds in instances where the last lender used is no longer available to process student loan funds, and lastly, book the appropriate entries for any funds determined to belong to the University that were not moved to the University operating accounts properly at the time of the transactions. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services Anticipated Completion Date: May 31, 2025

Prior Finding References

2023-003

About Cash Management →
2024-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2023-004QUESTIONED COSTS

Information on Federal Program ‒ Federal Work-Study Program (Assistance Listing Number 84.033) Criteria – Compliance Requirement N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time, and all amounts paid are appropriately earned. Condition – During our testing of the Federal Work-Study program, we noted the following:  For 3 students out of 10 sampled, from a population of 298 students who received Federal Work- Study, the University was unable to provide proper documentation to verify the student was not earning Federal Work-Study Financial Aid during scheduled class time.  For 2 students out of a population of 298 students who received Federal Work-Study, the University was unable to verify time punches, which resulted in overpayments of Federal Work-Study aid; however, the University was able to prove no refund was needed as there were offsetting hours that were subsequently claimed as allowable hours. Cause – Insufficient documentation related to internal controls in the Federal Work-Study program, resulting in 3 students appearing to work during scheduled class time without proper documentation on file, and 2 students whose time entered and paid were not able to be verified. Effect – The students and the University were not in compliance with the Federal Work-Study program guidelines. Questioned Costs – $1,533 Context – As noted in the condition, 5 total exceptions were found, which resulted in the students and the University not being in compliance with the program rules. Indication of a Repeat Finding – This is a repeat finding 2023-004 from prior year. Recommendation – We recommend the University ensure its internal controls, policies and procedures are followed on a consistent basis regarding the Federal Work-Study Program. Views of Responsible Officials – The University consistently emphasizes to both its students and student supervisors that students should not work during their scheduled class times, regardless of whether the class is cancelled or ends early. This expectation is reiterated during training sessions for supervisors and through publications distributed to them.

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Full finding narrative

Information on Federal Program ‒ Federal Work-Study Program (Assistance Listing Number 84.033) Criteria – Compliance Requirement N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time, and all amounts paid are appropriately earned. Condition – During our testing of the Federal Work-Study program, we noted the following:  For 3 students out of 10 sampled, from a population of 298 students who received Federal Work- Study, the University was unable to provide proper documentation to verify the student was not earning Federal Work-Study Financial Aid during scheduled class time.  For 2 students out of a population of 298 students who received Federal Work-Study, the University was unable to verify time punches, which resulted in overpayments of Federal Work-Study aid; however, the University was able to prove no refund was needed as there were offsetting hours that were subsequently claimed as allowable hours. Cause – Insufficient documentation related to internal controls in the Federal Work-Study program, resulting in 3 students appearing to work during scheduled class time without proper documentation on file, and 2 students whose time entered and paid were not able to be verified. Effect – The students and the University were not in compliance with the Federal Work-Study program guidelines. Questioned Costs – $1,533 Context – As noted in the condition, 5 total exceptions were found, which resulted in the students and the University not being in compliance with the program rules. Indication of a Repeat Finding – This is a repeat finding 2023-004 from prior year. Recommendation – We recommend the University ensure its internal controls, policies and procedures are followed on a consistent basis regarding the Federal Work-Study Program. Views of Responsible Officials – The University consistently emphasizes to both its students and student supervisors that students should not work during their scheduled class times, regardless of whether the class is cancelled or ends early. This expectation is reiterated during training sessions for supervisors and through publications distributed to them.

Corrective Action Plan

Finding 2024-002 Program: Federal Work-Study Program Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2023 - 2024 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time, and that all amounts paid are appropriately earned. University’s Response: The University continues to emphasize and reinforce with its students and student supervisors that, regardless of whether jobs are funded by the Federal Work Study program or by the institution, students must not be working during scheduled class hours regardless of whether the class is cancelled or let out early. The Student Employment Program holds annual training sessions for and provides updated publications to these responsible individuals. As part of the University student employment application process, students must submit their class schedule with their application. The University expects supervisors to utilize the student class schedules provided and keep work schedules distinct. The University also expects that supervisors continue to obtain students class schedules each semester and updates students work schedules accordingly each semester to ensure students are not working during times they are in class. The University continues to use the internal audit process it instituted in February 2023. A sample of student work records from the previous semester will be compared to students’ class schedules to ensure students are not working during class hours. This review will be performed by Michael Peeler, Vice President for Financial Affairs. Any violations of the school’s student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for corrective action to be taken. Corrective Action Plan: The University’s Student Employment Office continues to send monthly emails to student employee supervisors and to the student staff, reminding them of the student employment guidelines they are expected to abide by. This communication reminds them of their responsibility to adhere to student employment guidelines and their responsibility to keep their supervisor informed of any changes they may make to their class schedule that could require their work schedule to be adjusted. Since the hours of overpayment appeared to be resulting from students failing to clock out and managers failing to catch inaccurate hours of record (working for eight or more hours in a day, working overnight, etc.), further training and instruction to pay closer attention to these discrepancies so they are corrected at the time of approving timesheets has been provided to student employee supervisors as part of the monthly email communication. Student employee supervisors will continue to be expected to hold a mandatory meeting with their student staff at or before the start of each semester.The University’s internal audit process is also being expanded to be performed quarterly, twice each semester. This process will continue to sample student work records at the midpoint and end of the fall and spring semesters, where students’ class schedules are compared to hours worked to ensure students are not working during class hours. Michael Peeler, Vice President for Financial Affairs, will perform this review. Any violations of the school’s student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for corrective action to be taken. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services; Sandra Fantauzzi, Student Employment Program Manager; Marc Sears, Vice President of Human Resources; Brad Calloway, Senior Vice President for Business Affairs Anticipated Completion Date: March 31, 2025

Prior Finding References

2023-004

About Special Tests and Provisions →

FY 2023-05-31

LOW-RISK AUDITEE$72,842,427 federal awards expended

FAC accepted this audit on February 27, 2024 — management decision was due August 27, 2024.

2023-003
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001

Information on Federal Program ‒ Federal Family Education Loans Assistance Listing Number 84.032 Criteria – Compliance Requirement C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. Condition – During the audit, we noted the following: • The University has approximately $388,000 of excess cash held in a segregated federal funds cash account, which relates to awards from prior years. Cause – Prior management’s lack of oversight of student financial aid in prior years. The lack of proper oversight and insufficient internal controls resulted in excess cash received from third-party awarding agencies, which was not properly refunded, causing the University to have excess cash on hand. Effect – The University has excess cash on hand and was not in compliance with cash management requirements; however, the University has the funds properly held in an identifiable federal funds cash account, as they are currently investigating the best way to refund the excess cash. Questioned Costs – None. Context – We reviewed cash received and expended in a prior year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year. The University has continued to work to reconcile the excess cash and has consolidated the accounts to review down to 4 students in 2023. This is down from 438 students in the prior year. Indication of a Repeat Finding – This is a repeat finding 2022-001 from prior year. Recommendation – We recommend the University enhance internal controls over compliance with cash management requirements, as well as work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand. Views of Responsible Officials – The cash balance of federal financial aid funds does not pertain to the currently audited year. The University is diligently ensuring that these funds continue to remain separate while undergoing reconciliation and has safeguarded them from expenditure. Given the complexity of reviewing each student's history, we've enlisted the expertise of an external financial aid consulting firm experienced in reconciling FFEL loan programs.

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Full finding narrative

Information on Federal Program ‒ Federal Family Education Loans Assistance Listing Number 84.032 Criteria – Compliance Requirement C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. Condition – During the audit, we noted the following: • The University has approximately $388,000 of excess cash held in a segregated federal funds cash account, which relates to awards from prior years. Cause – Prior management’s lack of oversight of student financial aid in prior years. The lack of proper oversight and insufficient internal controls resulted in excess cash received from third-party awarding agencies, which was not properly refunded, causing the University to have excess cash on hand. Effect – The University has excess cash on hand and was not in compliance with cash management requirements; however, the University has the funds properly held in an identifiable federal funds cash account, as they are currently investigating the best way to refund the excess cash. Questioned Costs – None. Context – We reviewed cash received and expended in a prior year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year. The University has continued to work to reconcile the excess cash and has consolidated the accounts to review down to 4 students in 2023. This is down from 438 students in the prior year. Indication of a Repeat Finding – This is a repeat finding 2022-001 from prior year. Recommendation – We recommend the University enhance internal controls over compliance with cash management requirements, as well as work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand. Views of Responsible Officials – The cash balance of federal financial aid funds does not pertain to the currently audited year. The University is diligently ensuring that these funds continue to remain separate while undergoing reconciliation and has safeguarded them from expenditure. Given the complexity of reviewing each student's history, we've enlisted the expertise of an external financial aid consulting firm experienced in reconciling FFEL loan programs.

Corrective Action Plan

Finding 2023-003 Program: Federal Family Education Loans CFDA No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management University’s Response: The University has continued to ensure that these funds are not commingled and has protected them from being spent. Due to the discrepancies identified, it is necessary to review and compare each student's loan history between the University Information System, the lender rosters, and the National Student Loan Database System (NSLDS) records. This individual review and reconciliation process has proven to be tedious but necessary to identify funds that were never posted to student records, returned to lenders, or entered incorrectly in the three separate systems of record. Corrective Action Plan: With additional assistance, the University made further progress in identifying records with discrepancies. We reviewed the types of discrepancies identified with the DoE and, with their guidance, are detailing the individual student accounts to which funds need to be returned to correct the students' NSLDS loan records. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services Anticipated Completion Date: May 31, 2024

Prior Finding References

2022-001

About Cash Management →
2023-004
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2022-002QUESTIONED COSTS

Information on Federal Program ‒ Federal Work-Study Program Assistance Listing Number 84.033 Criteria – Compliance Requirement N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time, and that all amounts paid are appropriately earned. Condition – During our testing of the Federal Work-Study program, we noted the following: • For 3 students out of 10 sampled, from a population of 289 students who received Federal Work- Study, the University was unable to verify the student was not earning Federal Work-Study Financial Aid during scheduled class time. • For 52 students out of a population of 289 students who received Federal Work-Study, the University was unable to verify time punches, which resulted in overpayments of Federal Work- Study aid; however, the aid was subsequently returned by the University. Cause – Management oversight and insufficient internal controls in the Federal Work-Study program, resulting in 3 students appearing to work during scheduled class time, and 52 students whose time entered and paid were not able to be verified. Effect – The students and the University were not in compliance with the Federal Work-Study program guidelines. Questioned Costs – $10,077 Context – As noted in the condition, 55 total exceptions were found, which resulted in the students and the University not being in compliance with the program rules. Indication of a Repeat Finding – This is a repeat finding 2022-002 from prior year. Recommendation – We recommend the University ensure its internal controls, policies and procedures are followed on a consistent basis regarding the Federal Work-Study Program. Views of Responsible Officials – The University consistently emphasizes to both its students and student supervisors that students should not work during their scheduled class times, regardless of whether the class is cancelled or ends early. This expectation is reiterated during training sessions for supervisors and through publications distributed to them.

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Full finding narrative

Information on Federal Program ‒ Federal Work-Study Program Assistance Listing Number 84.033 Criteria – Compliance Requirement N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time, and that all amounts paid are appropriately earned. Condition – During our testing of the Federal Work-Study program, we noted the following: • For 3 students out of 10 sampled, from a population of 289 students who received Federal Work- Study, the University was unable to verify the student was not earning Federal Work-Study Financial Aid during scheduled class time. • For 52 students out of a population of 289 students who received Federal Work-Study, the University was unable to verify time punches, which resulted in overpayments of Federal Work- Study aid; however, the aid was subsequently returned by the University. Cause – Management oversight and insufficient internal controls in the Federal Work-Study program, resulting in 3 students appearing to work during scheduled class time, and 52 students whose time entered and paid were not able to be verified. Effect – The students and the University were not in compliance with the Federal Work-Study program guidelines. Questioned Costs – $10,077 Context – As noted in the condition, 55 total exceptions were found, which resulted in the students and the University not being in compliance with the program rules. Indication of a Repeat Finding – This is a repeat finding 2022-002 from prior year. Recommendation – We recommend the University ensure its internal controls, policies and procedures are followed on a consistent basis regarding the Federal Work-Study Program. Views of Responsible Officials – The University consistently emphasizes to both its students and student supervisors that students should not work during their scheduled class times, regardless of whether the class is cancelled or ends early. This expectation is reiterated during training sessions for supervisors and through publications distributed to them.

Corrective Action Plan

Finding 2023-004 Program: Federal Work-Study Program CFDA No.: 84.033 Federal Agency: Department of Education Award Year: FY 2022 - 2023 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time, and that all amounts paid are appropriately earned. University’s Response: The University continues to emphasize and reinforce with its students and student supervisors the importance of not working during scheduled class hours, regardless of whether their jobs are funded by the Federal Work Study program or by the institution. This policy applies even if classes are canceled or let out early. The Student Employment Program holds annual training sessions for these responsible individuals and provides updated publications. As part of the University's student employment application process, students are required to submit their class schedules. Supervisors are expected to utilize these schedules and ensure that work schedules do not conflict with class times. Additionally, supervisors are expected to obtain students' class schedules each semester and update their work schedules accordingly, to prevent students from working during class hours. In the University’s effort to meet the FISAP correction deadline and out of an abundance of caution, all questionable work-study transaction funds were returned and converted to institutionally full-paid hours for these students. This action aims to avoid penalizing the students for any errors and to rectify potential misappropriation of federal work-study funds. Corrective Action Plan: The University’s Student Employment Office continues to send monthly emails to student employee supervisors and the student staff, reminding them of the student employment guidelines they are expected to abide by. This communication emphasizes their responsibility to adhere to these guidelines and to keep their supervisor informed of any changes to their class schedule that may require adjustments to their work schedule. Student employee supervisors are expected to hold a mandatory meeting with their student staff at or before the start of each semester. The University also continues its internal audit process, implemented in February 2023. A sample of student work records from the previous semester will be compared to students’ class schedules to ensure they are not working during class hours. This review will be conducted by Brad Calloway, Senior Vice President for Business Affairs. Any violations of the school's student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for necessary corrective action. In mid-January 2024, the University will institute the Give Pulse platform, which will integrate with the University’s current HR/Payroll timekeeping system, Workday. The Give Pulse platform will assist in flagging students whose work hours fall outside the parameters of hours worked. Further training and instruction to pay closer attention to these discrepancies, such as failing to clock out or working for eight or more hours in a day, will be provided to student employee supervisors as part of the monthly email communication. The University is investigating the feasibility of implementing parameters within Workday that would notify student supervisors when their student workers are clocked in for more than 8 hours straight as well as when they are nearing 20 hours of work in a week. This notification would enable supervisors to ensure the accuracy of their students' clocked hours and make adjustments if necessary. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services; Sandra Fantauzzi, Student Employment Program Manager; Marc Sears, Vice President of Human Resources; Brad Calloway, Senior Vice President for Business Affairs Anticipated Completion Date: February 29, 2024

Prior Finding References

2022-002

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FY 2022-05-31

LOW-RISK AUDITEE$72,901,189 federal awards expended

FAC accepted this audit on February 23, 2023 — management decision was due August 23, 2023.

2022-001
Cash Management
REPEAT OF 2021-001OTHER MATTERS

Information on Federal Program - Federal Family Education Loans Assistance Listing Number 84.032 Criteria ? Compliance Requirement C ? Cash Management ? The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student?s account within 3 business days following the receipt of funds. Condition ? During the audit, we noted the following: ? The University has approximately $388,000 of excess cash held in a segregated federal funds cash account which relates to awards from prior years. Cause ? Prior management?s lack of oversight of student financial aid in prior years. The lack of proper oversight resulted in excess cash received from third party awarding agencies which was not properly refunded, causing the University to have excess cash on hand. Effect ? The University has excess cash on hand and was not in compliance with cash management requirements; however, the University has the funds properly held in an identifiable federal funds cash account, as they are currently investigating the best way to refund the excess cash. Questioned Costs ? None. Context ? We reviewed cash received and expended in a prior year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year. Indication of a Repeat Finding ? This is a repeat finding 2021-001 from prior year. Recommendation ? We recommend the University work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand. Views of Responsible Officials ? The cash balance of federal financial aid funds is not from the currently audited year but from many years ago. Because these funds go back to when the schools processed federal loans through the FFELP program, it has been difficult to reconcile these funds to the multiple lending institutions from which they came; some of which are no longer in existence. The University has taken great care not to comingle these funds and has protected them from being spent.

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Full finding narrative

Information on Federal Program - Federal Family Education Loans Assistance Listing Number 84.032 Criteria ? Compliance Requirement C ? Cash Management ? The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student?s account within 3 business days following the receipt of funds. Condition ? During the audit, we noted the following: ? The University has approximately $388,000 of excess cash held in a segregated federal funds cash account which relates to awards from prior years. Cause ? Prior management?s lack of oversight of student financial aid in prior years. The lack of proper oversight resulted in excess cash received from third party awarding agencies which was not properly refunded, causing the University to have excess cash on hand. Effect ? The University has excess cash on hand and was not in compliance with cash management requirements; however, the University has the funds properly held in an identifiable federal funds cash account, as they are currently investigating the best way to refund the excess cash. Questioned Costs ? None. Context ? We reviewed cash received and expended in a prior year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year. Indication of a Repeat Finding ? This is a repeat finding 2021-001 from prior year. Recommendation ? We recommend the University work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand. Views of Responsible Officials ? The cash balance of federal financial aid funds is not from the currently audited year but from many years ago. Because these funds go back to when the schools processed federal loans through the FFELP program, it has been difficult to reconcile these funds to the multiple lending institutions from which they came; some of which are no longer in existence. The University has taken great care not to comingle these funds and has protected them from being spent.

Corrective Action Plan

Finding 2022-001 Program: Federal Family Education Loans CFDA No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C ? Cash Management University?s Response: The University has continued to ensure these funds are not comingled and has protected them from spending. Because of the discrepancies identified, each student?s loan history must be reviewed and compared between the University Information System, the lender rosters, and the National Student Loan Database System (NSLDS) records. This individual review and reconciliation have proven to be a tedious but necessary process to identify the funds never posted to student records, returned to lenders, or entered incorrectly in the three separate systems of record. Corrective Action Plan: Between 2005 and 2010, the University isolated and identified eight hundred and eighty transactions for four hundred thirty-eight students they could not reconcile. The Senior Director of Student Financial Services is continuing to review each student?s loan history between the three systems of record to determine where the discrepancy lies. Once these discrepancies are identified for all 438 students, the University will consult with the DoE to determine the necessary action to correct these individual student accounts. Name of Responsible Person: Jonathan Mador, Senior Director of Student Financial Services Anticipated Completion Date: December 31, 2023

Prior Finding References

2021-001

About Cash Management →
2022-002
Special Tests & Provisions
REPEAT OF 2021-002QUESTIONED COSTSOTHER MATTERS

Information on Federal Program - Federal Work-Study Program Assistance Listing Number 84.033 Criteria ? Compliance Requirement N ? Special Tests and Provisions ? Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time. Condition ? During our testing of the Federal Work-Study program, we noted the following: ? For 5 students sampled, the University was unable to verify the student was not earning Federal Work-Study Financial Aid during scheduled class time. Cause ? Management oversight in the Federal Work-Study program, resulting in 5 students appearing to work during scheduled class time. Effect ? The student was not in compliance with the Federal Work-Study program guidelines. Questioned Costs ? $1,277 Context ? We found 5 exceptions as noted in the condition, which resulted in the students not being in compliance with the program rules. Indication of a Repeat Finding ? This is a repeat finding 2021-002 from prior year. Recommendation ? We recommend the University ensure its policies and procedures are followed on a consistent basis regarding the Federal Work-Study Program. Views of Responsible Officials ? The University has always emphasized to students working on campus, regardless of whether their job is funded by the Federal Work-Study program or by the institution, and student supervisors that students should not be working during scheduled class hours.

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Full finding narrative

Information on Federal Program - Federal Work-Study Program Assistance Listing Number 84.033 Criteria ? Compliance Requirement N ? Special Tests and Provisions ? Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time. Condition ? During our testing of the Federal Work-Study program, we noted the following: ? For 5 students sampled, the University was unable to verify the student was not earning Federal Work-Study Financial Aid during scheduled class time. Cause ? Management oversight in the Federal Work-Study program, resulting in 5 students appearing to work during scheduled class time. Effect ? The student was not in compliance with the Federal Work-Study program guidelines. Questioned Costs ? $1,277 Context ? We found 5 exceptions as noted in the condition, which resulted in the students not being in compliance with the program rules. Indication of a Repeat Finding ? This is a repeat finding 2021-002 from prior year. Recommendation ? We recommend the University ensure its policies and procedures are followed on a consistent basis regarding the Federal Work-Study Program. Views of Responsible Officials ? The University has always emphasized to students working on campus, regardless of whether their job is funded by the Federal Work-Study program or by the institution, and student supervisors that students should not be working during scheduled class hours.

Corrective Action Plan

Finding 2022-002 Program: Federal Work-Study Program CFDA No.: 84.033 Federal Agency: Department of Education Award Year: FY 2020 - 2021 Compliance Requirement: N ? Special Tests and Provisions ? Institutions are required to verify that students are not earning Federal Work Study Financial Aid during scheduled class time. University?s Response: The University continues to emphasize and reinforce with its students and student supervisors that, regardless of whether jobs are funded by the Federal Work-Study program or by the institution, students must not be working during scheduled class hours, irrespective of whether the class is canceled or let out early. The Student Employment Program holds annual supervisor training sessions and provides updated publications to these responsible individuals. As part of the University student employment application process, students must submit their class schedule with their application. The University expects supervisors to utilize the student class schedules provided and keep work schedules distinct. The University also expects supervisors to continue to obtain students? class schedules each semester and update students? work schedules accordingly each semester to ensure students are not working during times they are in class. Corrective Action Plan: In addition to the monthly email being sent to student employee supervisors reminding them of the student employment guidelines they are expected to enforce, a monthly email will also be sent to student staff. This communication will remind them of their responsibility to adhere to student employment guidelines and their commitment to keeping their supervisor informed of any changes they may make to their class schedule that could require their work schedule to be adjusted. Student employee supervisors will continue to be expected to hold a mandatory meeting with their student staff at or before the start of each semester. Furthermore, the University is instituting an internal audit process effective February 2023. A sample of student work records from the previous semester will be compared to students? class schedules to ensure students are not working during class hours. This review will be performed by Brad Calloway, Senior Vice President for Business Affairs. Any violations of the school student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for corrective action to be taken. Name of Responsible Person: Jonathan Mador, Senior Director of Student Financial Services; Sandra Fantauzzi, Student Employment Program Manager; Marc Sears, Vice President of Human Resources; Brad Calloway, Senior Vice President for Business Affairs Anticipated Completion Date: January 31, 2023

Prior Finding References

2021-002

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FY 2021-05-31

LOW-RISK AUDITEE$71,759,731 federal awards expended

FAC accepted this audit on February 27, 2022 — management decision was due August 27, 2022.

2021-001
Cash Management
REPEAT OF 2020-003OTHER MATTERS

Information on Federal Program ? Federal Family Education Loans CFDA 84.032 Criteria ? Compliance Requirement C ? Cash Management ? The University must return all excess cash received from the Department of Education in a timely manner, if funds are not credited to an enrolled student?s account within 3 business days following the receipt of funds. Condition ? During the audit, we noted the following: ? The University has approximately $388,000 of excess cash held in a segregated federal funds cash account which relates to awards from prior years. Cause ? Prior management?s lack of oversight of student financial aid in prior years. The lack of proper oversight resulted in excess cash received from third party awarding agencies which was not properly refunded, causing the University to have excess cash on hand. Effect ? The University has excess cash on hand; however, the University has the funds properly held in an identifiable federal funds cash account, as they are currently investigating the best way to refund the excess cash. Questioned Costs ? None. Context ? We reviewed cash received and expended in a prior year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year. Indication of a Repeat Finding ? This is a repeat finding 2020-003 from prior year. Recommendation ? We recommend the University work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand.

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Full finding narrative

Information on Federal Program ? Federal Family Education Loans CFDA 84.032 Criteria ? Compliance Requirement C ? Cash Management ? The University must return all excess cash received from the Department of Education in a timely manner, if funds are not credited to an enrolled student?s account within 3 business days following the receipt of funds. Condition ? During the audit, we noted the following: ? The University has approximately $388,000 of excess cash held in a segregated federal funds cash account which relates to awards from prior years. Cause ? Prior management?s lack of oversight of student financial aid in prior years. The lack of proper oversight resulted in excess cash received from third party awarding agencies which was not properly refunded, causing the University to have excess cash on hand. Effect ? The University has excess cash on hand; however, the University has the funds properly held in an identifiable federal funds cash account, as they are currently investigating the best way to refund the excess cash. Questioned Costs ? None. Context ? We reviewed cash received and expended in a prior year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year. Indication of a Repeat Finding ? This is a repeat finding 2020-003 from prior year. Recommendation ? We recommend the University work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand.

Corrective Action Plan

Corrective Action Plan Finding 2021-001 Program: Federal Family Education Loans CFDA No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C ? Cash Management University?s Response: The University has continued to ensure these funds are not comingled and has safeguarded from spending. Because these funds go several years back to when the University processed Federal loans through the FFEL program, it continues to prove difficult to reconcile these funds to the multiple lending institutions from which they came; some of which are no longer in existence. Corrective Action Plan: The Senior Director of Student Financial Services is continuing to identify the individuals associated with the funds in question to make the necessary determination of these funds. He has isolated those transactions between 2005 and 2009, with only 2010 remaining before further reviewing and reconcile those records and deciding what further action the University needs to take on the funds in question. Name of Responsible Person: Jonathan Mador, Senior Director of Student Financial Services Anticipated Completion Date: September 30, 2022

Prior Finding References

2020-003

About Cash Management →
2021-002
Special Tests & Provisions
REPEAT OF 2020-002QUESTIONED COSTSOTHER MATTERS

Information on Federal Program ? Federal Work-Study Program CFDA 84.033 Criteria ? Compliance Requirement N ? Special Tests and Provisions ? Institutions are required to verify students are not earning Federal Work Study Financial Aid during scheduled class time. Condition ? During our testing of the Federal Work Study program, we noted the following: ? For 1 of the 10 students sampled, the University was unable to verify the student was not earning Federal Work Study Financial Aid during scheduled class time. Cause ? Management oversight in the Federal Work Study program, resulting in one student appearing to work during scheduled class time. Effect ? The student was not in compliance with the Federal Work Study program guidelines. Questioned Costs ? $358 Context ? We tested a sample of 10 students and found 1 exception as noted in the condition, which resulted in a student not being in compliance with the program rules. Indication of a Repeat Finding ? This is a repeat finding 2020-002 from prior year. Recommendation ? We recommend the University ensure its policies and procedures are followed on a consistent basis regarding the Federal Work-Study Program.

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Full finding narrative

Information on Federal Program ? Federal Work-Study Program CFDA 84.033 Criteria ? Compliance Requirement N ? Special Tests and Provisions ? Institutions are required to verify students are not earning Federal Work Study Financial Aid during scheduled class time. Condition ? During our testing of the Federal Work Study program, we noted the following: ? For 1 of the 10 students sampled, the University was unable to verify the student was not earning Federal Work Study Financial Aid during scheduled class time. Cause ? Management oversight in the Federal Work Study program, resulting in one student appearing to work during scheduled class time. Effect ? The student was not in compliance with the Federal Work Study program guidelines. Questioned Costs ? $358 Context ? We tested a sample of 10 students and found 1 exception as noted in the condition, which resulted in a student not being in compliance with the program rules. Indication of a Repeat Finding ? This is a repeat finding 2020-002 from prior year. Recommendation ? We recommend the University ensure its policies and procedures are followed on a consistent basis regarding the Federal Work-Study Program.

Corrective Action Plan

Corrective Action Plan Finding 2021-002 Program: Federal Work-Study Program CFDA No.: 84.033 Federal Agency: Department of Education Award Year: FY 2020 - 2021 Compliance Requirement: N ? Special Tests and Provisions ? Institutions are required to verify students are not earning Federal Work Study Financial Aid during scheduled class time. University?s Response: The University emphasizes and reinforces with students and student supervisors that, regardless of whether jobs are funded by the Federal Work Study program or by the institution, students should not be working during scheduled class hours. The Student Employment Program has covered this topic in training sessions for supervisors and publications sent to these responsible individuals. As part of the University student employment application process, students must submit their class schedule with their application. The University expects supervisors to utilize the student class schedules provided and ensure work schedules are not allowed to overlap. Corrective Action Plan: The Student Employment Program is putting responsibility on the student employment supervisors to continue to obtain student class schedules with every new semester to ensure students are not working duing times they are in class. The University is adopting a new rule that no student is to work during a scheduled class time regardless of whether the class is cancelled or let out early. Additional email communication is being sent to student employee supervisors on a monthly basis reminding them of the guidelines for all student employees they are expected to enforce and communicate to their student staff. Furthermore, student employee supervisors are expected to hold a mandatory meeting with their student staff at or before the start of each semester. Name of Responsible Person: Jonathan Mador, Senior Director of Student Financial Services, and Whitney Neal, Human Resources Director. Anticipated Completion Date: January 31, 2022

Prior Finding References

2020-002

About Special Tests and Provisions →

FY 2020-05-31

LOW-RISK AUDITEE$63,398,489 federal awards expended

FAC accepted this audit on March 7, 2021 — management decision was due September 7, 2021.

2020-001
Special Tests & Provisions
OTHER MATTERS

2020-001 ? ReportingInformation on Federal Program ? Federal Direct Student Loans CFDA 84.268Criteria ? Compliance Requirement N ? Special Tests and Provisions ? Institutions are required to report enrollment information under Pell grant, Direct and FFEL loan programs via the National Student Loan Data System (NSLDS).Condition ? During our testing of NSLDS enrollment reporting, we noted the following:? 1 of the 20 students sampled was not included in the NSLDS enrollment reporting roster for the semester tested.Cause ? Management oversight in correcting NSLDS enrollment reporting, resulting in this student not being included in the roster for the proper timeframe.Effect ? The student was not included in the roster in a timely manner; however, the University subsequently updated the reporting roster to include the student.Questioned Costs ? NoneContext ? We tested a sample of 20 students and found 1 exception as noted in the condition, which resulted in a student not being included in the reporting roster in the correct timeframe.Indication of a Repeat Finding ? This is not a repeat finding from prior year.Recommendation ? We recommend the University ensure its policies and procedures are followed on a consistent basis when updating NSLDS enrollment reporting.

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2020-001 ? ReportingInformation on Federal Program ? Federal Direct Student Loans CFDA 84.268Criteria ? Compliance Requirement N ? Special Tests and Provisions ? Institutions are required to report enrollment information under Pell grant, Direct and FFEL loan programs via the National Student Loan Data System (NSLDS).Condition ? During our testing of NSLDS enrollment reporting, we noted the following:? 1 of the 20 students sampled was not included in the NSLDS enrollment reporting roster for the semester tested.Cause ? Management oversight in correcting NSLDS enrollment reporting, resulting in this student not being included in the roster for the proper timeframe.Effect ? The student was not included in the roster in a timely manner; however, the University subsequently updated the reporting roster to include the student.Questioned Costs ? NoneContext ? We tested a sample of 20 students and found 1 exception as noted in the condition, which resulted in a student not being included in the reporting roster in the correct timeframe.Indication of a Repeat Finding ? This is not a repeat finding from prior year.Recommendation ? We recommend the University ensure its policies and procedures are followed on a consistent basis when updating NSLDS enrollment reporting.

Corrective Action Plan

Corrective Action PlanFinding 2020-001Program: Federal Direct Student LoansCFDA No.: 84.268Federal Agency: Department of EducationAward Year: FY 2019 ? 2020Compliance Requirement: N ? Special Tests and Provisions ? Institutions are required to report enrollment information under Pell grant, Direct and FFEL loan programs via the National Student Loan Data System (NSLDS).University?s Response: The student in question required another institution to make necessary corrections to their reporting before our reporting could be accepted. The University should have taken further measures to monitor and resolve this issue timelier upon the other institution making the necessary corrections. As a recipient of federal funding, the student?s federal aid should have been placed on hold until the required reporting was completed.Corrective Action Plan: The University has taken steps to correct reporting errors within the 10-day requirement. The University prcesses our enrollment reporting monthly through the National Student Clearinghouse who then does the necessary reporting for the University to NSLDS. Upon receiving any error reports from the National Student Clearinghouse, the University Registrar?s Office will share those findings immediately with our Financial Planning Office. The Financial Planning Office will review those errors and, for those receving federal financial aid, will place all aid on hold for the student until the matter can be resolved. Where the issue cannot be resolved by the Office of Financial Planning or any other office within the University on the student?s behalf, the Registrar?s Office will also reach out to the student to resolve the error.Name of Responsible Person: Jonathan Mador, Senior Director of Student Financial Services, and Danny Brooks, Assistant Vice President and University Registrar.Anticipated Completion Date: January 10, 2021

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2020-002
Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

2020-002 ? Federal Work Study Hours WorkedInformation on Federal Program ? Federal Work-Study Program CFDA 84.033Criteria ? Compliance Requirement N ? Special Tests and Provisions ? Institutions are required to verify students are not earning Federal Work Study Financial Aid during scheduled class time.Condition ? During our testing of the Federal Work Study program, we noted the following:? For 1 of the 10 students sampled, the University was unable to verify the student was not earning Federal Work Study Financial Aid during scheduled class time.Cause ? Management oversight in the Federal Work Study program, resulting in one student appearing to work during scheduled class time.Effect ? The student was not in compliance with the Federal Work Study program guidelines.Questioned Costs ? $178Context ? We tested a sample of 10 students and found 1 exception as noted in the condition, which resulted in a student appearing to not be in compliance with the program rules.Indication of a Repeat Finding ? This is not a repeat finding from prior year.Recommendation ? We recommend the University ensure its policies and procedures are followed on a consistent basis regarding the Federal Work-Study Program.

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2020-002 ? Federal Work Study Hours WorkedInformation on Federal Program ? Federal Work-Study Program CFDA 84.033Criteria ? Compliance Requirement N ? Special Tests and Provisions ? Institutions are required to verify students are not earning Federal Work Study Financial Aid during scheduled class time.Condition ? During our testing of the Federal Work Study program, we noted the following:? For 1 of the 10 students sampled, the University was unable to verify the student was not earning Federal Work Study Financial Aid during scheduled class time.Cause ? Management oversight in the Federal Work Study program, resulting in one student appearing to work during scheduled class time.Effect ? The student was not in compliance with the Federal Work Study program guidelines.Questioned Costs ? $178Context ? We tested a sample of 10 students and found 1 exception as noted in the condition, which resulted in a student appearing to not be in compliance with the program rules.Indication of a Repeat Finding ? This is not a repeat finding from prior year.Recommendation ? We recommend the University ensure its policies and procedures are followed on a consistent basis regarding the Federal Work-Study Program.

Corrective Action Plan

Corrective Action PlanFinding 2020-002Program: Federal Work-Study ProgramCFDA No.: 84.033Federal Agency: Department of EducationAward Year: FY 2019 ? 2020Compliance Requirement: N ? Special Tests and Provisions ? Institutions are required to verify students are not earning Federal Work Study Financial Aid during scheduled class time.University?s Response: The University has always emphasized to students working on campus, regardless of whether their job is funded by the Federal Work Study program or by the institution, and student supervisors that students should not be working during scheduled class hours.Corrective Action Plan: The University has reinforced with its students and student supervisors that under no circumstances should students be working during times they are scheduled to be in class. The Student Employment Program will cover this topic in detail in training sessions for student worker supervisors and publications sent to these responsible individuals. As part of the University student employment application process, students are required to submit their class schedule as part of their application. Training will include instructions for supervisors to utilize the student class schedules provided and ensure work schedules are not allowed to overlap.Name of Responsible Person: Jonathan Mador, Senior Director of Student Financial Services, and Whitney Neal, Human Resources Director.Anticipated Completion Date: February 28, 2021

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2020-003
Cash Management
REPEAT OF 2019-002OTHER MATTERS

2020-003 ? Cash ManagementInformation on Federal Program ? Federal Family Education Loans CFDA 84.032Criteria ? Compliance Requirement C ? Cash Management ? The University must return all excess cash received from the Department of Education in a timely manner, if funds are not credited to an enrolled student?s account within 3 business days following the receipt of funds.Condition ? During the audit, we noted the following:? The University has approximately $388,000 of excess cash held in a segregated Federal Funds cash account which relates to awards from prior years.Cause ? Prior management lack of oversight of student financial aid in prior years. The lack of proper oversight resulted in excess cash received from third party awarding agencies which was not properly refunded, causing the University to have excess cash on hand.Effect ? The University has excess cash on hand; however, the University has the funds properly held in an identifiable Federal Funds cash account, as they are currently investigating the best way to refund the excess cash.Questioned Costs ? NoneContext ? We reviewed cash received and expended in the prior year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year.Indication of a Repeat Finding ? This is a repeat finding from prior year.Recommendation ? We recommend the University work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand.

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2020-003 ? Cash ManagementInformation on Federal Program ? Federal Family Education Loans CFDA 84.032Criteria ? Compliance Requirement C ? Cash Management ? The University must return all excess cash received from the Department of Education in a timely manner, if funds are not credited to an enrolled student?s account within 3 business days following the receipt of funds.Condition ? During the audit, we noted the following:? The University has approximately $388,000 of excess cash held in a segregated Federal Funds cash account which relates to awards from prior years.Cause ? Prior management lack of oversight of student financial aid in prior years. The lack of proper oversight resulted in excess cash received from third party awarding agencies which was not properly refunded, causing the University to have excess cash on hand.Effect ? The University has excess cash on hand; however, the University has the funds properly held in an identifiable Federal Funds cash account, as they are currently investigating the best way to refund the excess cash.Questioned Costs ? NoneContext ? We reviewed cash received and expended in the prior year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year.Indication of a Repeat Finding ? This is a repeat finding from prior year.Recommendation ? We recommend the University work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand.

Corrective Action Plan

Corrective Action PlanFinding 2020-003Program: Federal Family Education LoanCFDA No.: 84.032Federal Agency: Department of EducationAward Year: VariousCompliance Requirement: C ? Cash ManagementUniversity?s Response:The cash balance of federal financial aid funds is not from the currently audited year but from many years ago. Because these funds go back to when the schools processed federal loans through the FFELP program, it has been difficult to reconcile these funds to the multiple lending institutions from which they came; some of which are no longer in existence. The University has taken great care not to comingle these funds and has protected them from being spent.Corrective Action Plan:The Senior Director of Student Financial Services is continuing to work to identify the individuals associated with the funds in question to make the necessary determination of these funds.Name of Responsible Person: Jonathan Mador, Senior Director of Student Financial ServicesAnticipated Completion Date: May 31, 2021

Prior Finding References

2019-002

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FY 2019-05-31

LOW-RISK AUDITEE$56,234,184 federal awards expended

FAC accepted this audit on February 3, 2020 — management decision was due August 3, 2020.

2019-001
Special Tests & Provisions
OTHER MATTERS

Section III ? Federal Award Findings and Questioned Costs 2019-001 ? Activities Allowed or Unallowed; Allowable Costs/Cost Principles Information on Federal Program ? Federal Direct Loans CFDA 84.268 Criteria ? Compliance Requirement N ? Special Tests and Provisions ? For all Federal Direct Loan funds, the University must refund all credit balances to students within 14 days. Condition ? During our testing of student accounts, we noted the following: ? 1 of the 70 student accounts sampled did not have a refund to the student within the 14 day timeframe; however, the University properly disbursed the correct amount and refunded the credit balance to the student 20 days after the credit balance was created. Cause ? Management oversight in processing student aid, resulting in a credit balance that was not refunded in the proper timeframe. Effect ? The student was not refunded the credit balance in a timely manner; however, the University properly disbursed the correct amount and refunded the credit balance to the student. Questioned Costs ? None Context ? We tested a sample of 70 students and found 1 exception as noted in the condition, which resulted in a student refund not being issued in the correct timeframe. Repeat Finding ? This is not a repeat finding from prior year. Recommendation ? We recommend the University ensure its policies and procedures are followed on a consistent basis when awarding students and refunding credit balances. Views of Responsible Officials and Planned Corrective Actions ? The University is not in agreement with this finding seeing that the student in question received funding from multiple sources including Title IV and the initial refund was delayed in order to ensure the total funding did not result in an over-award. Upon its review, it was determined that an over-award existed and the student's total funding was reduced. The University has, however, taken steps in the crediting of aid and refund processing to make certain all necessary reviews are completed within the 14-day timeframe to further ensure compliance with future refunds.

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Section III ? Federal Award Findings and Questioned Costs 2019-001 ? Activities Allowed or Unallowed; Allowable Costs/Cost Principles Information on Federal Program ? Federal Direct Loans CFDA 84.268 Criteria ? Compliance Requirement N ? Special Tests and Provisions ? For all Federal Direct Loan funds, the University must refund all credit balances to students within 14 days. Condition ? During our testing of student accounts, we noted the following: ? 1 of the 70 student accounts sampled did not have a refund to the student within the 14 day timeframe; however, the University properly disbursed the correct amount and refunded the credit balance to the student 20 days after the credit balance was created. Cause ? Management oversight in processing student aid, resulting in a credit balance that was not refunded in the proper timeframe. Effect ? The student was not refunded the credit balance in a timely manner; however, the University properly disbursed the correct amount and refunded the credit balance to the student. Questioned Costs ? None Context ? We tested a sample of 70 students and found 1 exception as noted in the condition, which resulted in a student refund not being issued in the correct timeframe. Repeat Finding ? This is not a repeat finding from prior year. Recommendation ? We recommend the University ensure its policies and procedures are followed on a consistent basis when awarding students and refunding credit balances. Views of Responsible Officials and Planned Corrective Actions ? The University is not in agreement with this finding seeing that the student in question received funding from multiple sources including Title IV and the initial refund was delayed in order to ensure the total funding did not result in an over-award. Upon its review, it was determined that an over-award existed and the student's total funding was reduced. The University has, however, taken steps in the crediting of aid and refund processing to make certain all necessary reviews are completed within the 14-day timeframe to further ensure compliance with future refunds.

Corrective Action Plan

Corrective Action Plan Finding 2019-001 Program: Federal Direct Loans CFDA No.: 84.268 Federal Agency: Department of Education Award Year: FY 2018 - 2019 Compliance Requirement: N ? Special Tests and Provisions University?s Response: The University is not in agreement with this finding seeing that the student in question received funding from multiple sources including Title IV and the initial refund was delayed in order to ensure the total funding did not result in an over-award. Upon its review, it was determined that an over-award existed and the student's total funding was reduced. Corrective Action Plan: The University has taken steps in the crediting of aid and refund processing to make certain all necessary reviews are completed within the 14-day timeframe to further ensure compliance with future refunds. These steps included coordinating and agreeing aid disbursements dates in advance of the start of the terms between the Senior Associate Director of Financial Planning and Associate Director Student Accounts Offices to ensure adequate staff resources are available for review and processing refunds by determined deadlines. Name of Responsible Person: Jonathan Mador, Senior Director of Student Financial Services Anticipated Completion Date: January 10, 2020

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2019-002
Cash Management
OTHER MATTERS

Section III ? Federal Award Findings and Questioned Costs (Concluded) 2019-002 ? Cash Management Information on Federal Program ? Federal Family Education Loans CFDA 84.032 Criteria ? Compliance Requirement C ? Cash Management ? The University must return all excess cash received from the Department of Education in a timely manner, if funds are not credited to an enrolled student?s account within 3 business days following the receipt of funds. Condition ? During the audit, we noted the following: ? The University has approximately $388,000 of excess cash held in a segregated Federal Funds cash account which relates to awards from prior years. Cause ? Prior management lack of oversight of student financial aid in prior years. The lack of proper oversight resulted in excess cash received from third party awarding agencies which was not properly refunded, causing the University to have excess cash on hand. Effect ? The University has excess cash on hand; however, the University has the funds properly held in an identifiable Federal Funds cash account, as they are currently investigating the best way to refund the excess cash. Questioned Costs ? None Context ? We reviewed cash received and expended in the current year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year. Repeat Finding ? This is not a repeat finding from prior year. Recommendation ? We recommend the University work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand. Views of Responsible Officials and Planned Corrective Actions ? The cash balance of federal financial aid funds is not from the currently audited year but from many years ago. Because these funds go back to when the schools processed federal loans through the FFEL program, it has been difficult to reconcile these funds to the multiple lending institutions from which they came; some of which are no longer in existence. The University has taken great care not to comingle these funds and has protected them from being spent. The University has established a separate payable for this cash balance and is currently working to reconcile the difference to then determine who these funds should be returned to or properly recognized.

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Section III ? Federal Award Findings and Questioned Costs (Concluded) 2019-002 ? Cash Management Information on Federal Program ? Federal Family Education Loans CFDA 84.032 Criteria ? Compliance Requirement C ? Cash Management ? The University must return all excess cash received from the Department of Education in a timely manner, if funds are not credited to an enrolled student?s account within 3 business days following the receipt of funds. Condition ? During the audit, we noted the following: ? The University has approximately $388,000 of excess cash held in a segregated Federal Funds cash account which relates to awards from prior years. Cause ? Prior management lack of oversight of student financial aid in prior years. The lack of proper oversight resulted in excess cash received from third party awarding agencies which was not properly refunded, causing the University to have excess cash on hand. Effect ? The University has excess cash on hand; however, the University has the funds properly held in an identifiable Federal Funds cash account, as they are currently investigating the best way to refund the excess cash. Questioned Costs ? None Context ? We reviewed cash received and expended in the current year, noting the University has additional funds on hand from prior awarding years. All current year funds were properly received and disbursed with no excess cash on hand from the current year. Repeat Finding ? This is not a repeat finding from prior year. Recommendation ? We recommend the University work with current and prior awarding agencies to determine the appropriate course of action to return the excess cash on hand. Views of Responsible Officials and Planned Corrective Actions ? The cash balance of federal financial aid funds is not from the currently audited year but from many years ago. Because these funds go back to when the schools processed federal loans through the FFEL program, it has been difficult to reconcile these funds to the multiple lending institutions from which they came; some of which are no longer in existence. The University has taken great care not to comingle these funds and has protected them from being spent. The University has established a separate payable for this cash balance and is currently working to reconcile the difference to then determine who these funds should be returned to or properly recognized.

Corrective Action Plan

Corrective Action Plan Finding 2019-002 Program: Federal Family Education Loan CFDA No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C ? Cash Management University?s Response: The cash balance of federal financial aid funds is not from the currently audited year but from many years ago. Because these funds go back to when the schools processed federal loans through the FFELP program, it has been difficult to reconcile these funds to the multiple lending institutions from which they came; some of which are no longer in existence. The University has taken great care not to comingle these funds and has protected them from being spent. Corrective Action Plan: The University established a separate payable for this cash balance and is currently working to reconcile the difference to then determine if these funds should be returned or properly recognized. In conjunction with the Senior Director of Student Financial Services, the former Director of Financial Aid is working with the University in a consulting capacity and is tasked with identifying the individuals associated with the funds in question to make the necessary determination of these funds Name of Responsible Person: Jonathan Mador, Senior Director of Student Financial Services Anticipated Completion Date: March 31, 2020

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FY 2018-05-31

LOW-RISK AUDITEE$50,612,959 federal awards expended

FAC accepted this audit on February 26, 2019 — management decision was due August 26, 2019.

2018-001
Eligibility
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2017-05-31

LOW-RISK AUDITEE$42,149,148 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 20, 2018 — management decision was due August 20, 2018.

FY 2016-05-31

LOW-RISK AUDITEE$33,576,155 federal awards expended

FAC accepted this audit on January 8, 2017 — management decision was due July 8, 2017.

2016-001
Other
REPEAT OF 2012-002OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2012-002

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