Lander UniversityHigher Education

2025-002 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Untimely Return of Title IV Refunds (Significant Deficiency) Condition: From a population of 40 students that unofficially withdrew during the academic year, we tested four students and noted that all four students required refund calculations. R2T4 calculations were not prepared for three of the four students. Criteria: For a student who withdrawals, without providing notification, from a school that is not required to take attendance, the school must determine the withdrawal date no later than 30 days after the end of the earlier of (1) the payment period or the period of enrollment (as applicable), (2) the academic year, or (3) the student’s educational program. An institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew (34 CFR Section 668.22(a)(6)(j)(1)). Cause: Controls to ensure timely preparation of Title IV refunds did not function as related to the condition above. Effect: R2T4 calculations were not prepared for three students tested that unofficially withdrew resulting in untimely return of funds to the Department of Education. Repeat Finding from a Prior Year: No Recommendation: We recommend the University review and update its procedures to ensure timely preparation of Title IV refunds for students that unofficial withdrawal. View of Responsible Officials: Lander University acknowledges the finding related to the untimely return of Title IV funds and recognizes the seriousness of this compliance matter. The University has conducted a comprehensive review of its processes related to the identification of unofficial withdrawals and the timely completion of Return of Title IV (R2T4) calculations. The review determined that the prior process relied on a single point of control within the Financial Aid Office to identify unofficial withdrawals and initiate R2T4 calculations. During the period under review, that control did not function as intended, resulting in certain students not being identified in a timely manner and required R2T4 calculations not being completed within regulatory timeframes. In response, the University has redesigned the control environment governing unofficial withdrawal identification and R2T4 processing to introduce multiple, independent points of review and verification, and to formalize cross-office responsibilities. Under the revised process, faculty are required, pursuant to institutional grading policy, to document the student’s last date of academically related activity when assigning grades indicative of non-participation. At the conclusion of each academic term, the Registrar’s Office performs a structured review of students receiving grades associated with non-attendance to identify those who may have unofficially withdrawn from all coursework. The Registrar reviews the documented information for completeness and consistency and records the verified last date of attendance or participation in the student information system. The verified information is then provided to the Financial Aid Office, which completes the required R2T4 calculation within established timelines. The process now includes multiple levels of review, including supervisory and director-level oversight within Financial Aid, to ensure calculations are completed accurately and timely. Relevant information is also communicated to Student Accounts and the Registrar to ensure appropriate billing, notification, and enrollment reporting. These revised procedures have been implemented and are designed to eliminate reliance on a single control, strengthen accountability across offices, and ensure timely identification of unofficial withdrawals and prompt return of Title IV funds. Through these corrective actions, the University has strengthened its internal controls and is committed to maintaining full compliance with federal Title IV requirements. Joseph T. Greenthal Vice President for Finance and Administration Lander University

Finding Number: 2022-002 - Internal Controls over Compliance with Education Stabilization Fund Requirements Institutional Response: The responsibility of ensuring expenditures incurred due to the COVID-19 pandemic met the requirements established under HEERF as eligible reimbursement rested with the former Office of Business and Administration. The vice president and the controller were the two lead finance officers for the institution and the controller was the grant ?Project Director? as defined by G5. Given the volume of purchases and the speed in which institutions had to act, larger committees to review expenditures were not feasible. The procurement department resided with this division, so the review of all anticipated HEERF eligible expenses by the leader of the division and the second most senior ranking in the division seemed adequate. The office also accounted for expenditures to HEERF funding by creating dedicated general ledger funds for only HEERF related expenses that they reviewed. The institution could not have foreseen both positions would be vacant before the closing of the grant period. The review process of each expenditure passing through the direct oversight of the vice president and the controller was still a sound practice that continued through the expenditures reported and claimed against HEERF funding. Corrective Action: While Lander University believes its expenditure review process under HEERF was adequate by establishing direct purchasing oversight with both the vice president and controller position, despite the fact both position were eventually vacated, the University acknowledges that a process or procedure established should continue to be honored. In the event a practice or procedure needs to be altered or updated, additional document supporting the change should also exist. The discontinuation of an internal form used to establish approvals specific to reviewing expenditures associated with HEERF did not impact the process as the upper-management review and sign-off still occurred and all procurements passed through the state procurement process. Lander University will ensure a more robust process of approvals is established for future federal funding should the institution experience turnover in key roles.

Finding Number: 2022-003 - Allowable Costs Institutional Response: It is Lander University?s position the measures taken to utilize previously leased space to socially distance nursing students, in a simulation lab setting, falls within the guidance provided. While HEERF funding was not to be used for construction or capital outlays, an exception was provided in the FAQ regarding, and helping to further define, ?minor remodeling.? The FAQ provides limited, and not all-inclusive, examples of ?minor remodeling.? The most specific examples given were under question #24. ?What are some examples of permissible ?minor remodeling? that HEERF grant funds may support under the definition in 34 CFR ? 77.1?? An excerpt of the answer is provided: ?Some examples of permissible minor remodeling may include, but not limited to: ? The installation or renovation of an HVAC system, to help with air filtration to prevent the spread of COVID-19. ? The purchase or cost of the installation of ?room dividers? within a previously completed building to increase social distancing.? The building in question was preexisting, occupiable, and did not receive structural improvements or additions to the building. The HVAC systems was renovated to meet the CDC and ASHRAE recommendations to improved air quality through a significant increase of bringing in outside make up air. The institution expended $162,535 in direct HVAC costs according to the final pay app - schedule of values with additional associated expenses in both plumbing and electrical, totaling more than $281,000. The institution did partition a large, open space into two separate areas to further divide students for social distancing measures. Taking these measures allowed the institution to keep preparing nurses for the workforce at a critical time during the pandemic. Lander University did not have to reduce class sizes, or resort to limited online learning for lab experience because it had the ability to spread out between two locations: the main nursing building and this extension location for simulation. The simulation space worked to mimic clinical experience with essential equipment for training nursing students. Corrective Action: The University maintains its position the expenses incurred fall within provided guidance; however, should the U.S. Department of Education disagree as part of their auditing procedures, Lander University will work to reach a remedy with the agencies in authority over the HEERF program. Responsible department for corrective action: Office of Accounting and Controls and the Office of Finance and Administration

Finding Number: 2022-004 - Lost Revenue Calculations Institutional Response: Lander University agrees the multiple methodologies used by past administrators may be inconsistent from the guidance stating the same methodology must use a consistent baseline. The University?s lost revenue amounts exceed the amounts claimed against all three rounds of HEERF. Using two forms of lost revenue as defined by the Lost Revenue Frequently Asked Questions, Published March 19, 2021, the university is able to calculate lost revenues under ?Academic Sources? and as ?a comparison to previously budgeted revenue or projected revenue for the period?? as stated in question #3 and #9, to satisfy all draws of lost revenue. Corrective Action: Lander University will retain the currently documented evidence to support lost revenue as calculated for all monthly and quarterly submissions regarding HEERF expenditures; however, the University will also undertake a secondary calculation that justifies lost revenue draws using a more consistent methodology, also supported through provided guidance. Such calculations will be generated based on Academic Sources, such as ?tuition, fees, and institutional charges (including unpaid student accounts receivable and other student accounts debts) as listed in the FAQ question/answer #3, and the ?comparison to previously budgeted revenue or projected revenue for the period? listed in question/answer #9. Responsible department for corrective action: Office of Accounting and Controls and the Office of Finance and Administration

Finding Number: 2022-005 - Procurement Compliance Institutional Response: Lander University acknowledges this one sample procurement lacked adequate competitive quotes to support the reasonableness of price. It is believed the procurement was rushed in an effort to have authorized and appropriate PPE available to incoming students. With the purchase equating to $2.03 per compliant cloth mask under the CDC guidance at the time, this purchase was reasonable. The observation is correct that the supporting documentation did not present two additional quotes. This procurement was initiated by the campus bookstore staff, who typically are exempt from state procurement under Section 11-35-710 when purchasing items for resale. While this purchase was not for resale, the staff in the bookstore followed their typically acceptable purchasing structure, not realizing the source of funding placed the procurement back under state requirements. This effort was in support of the institution, but it bypassed the more stringent process of purchases passing through the procurement office. While debarment information is shared via standardized terms and conditions documents associated with purchase orders and solicitations, the department is left to check various websites created for state and federal purposes, listing those vendors the university is not to do business with. Such searches were not documented in the procurement files. Doing so is not a necessary step, but the University is aware it needs to ensure prospective vendors are first reviewed against debarment lists. Corrective Action: Lander University will strive to improve controls. Bookstore employees will be trained on state procurement procedures when using non-exempt funds, although such procurements are extremely rare. The procurement department will engage the staff to make sure they understand which funds and purchases are exempt from state procurement and which are not. The Office of Procurement will create a written procedure on debarments, detailing out how to verify a vendor is clear to do business with Lander University. Lander University will add a section to the procurement requisition form to acknowledge the vendor was thoroughly reviewed against active lists. Responsible department for corrective action: Office of Procurement and the Office of Finance and Administration