South Carolina State University

Finding 2025-001 – N. Special Tests and Provisions – Enrollment Reporting – Program Level Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.   Condition – The condition was as follows: Program Level: For certain students that had enrollment status changes, the University incorrectly reported enrollment status, the program begin date, and/or the program enrollment effective date. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs – None. Context – The context is as follows: Program Level: • For 2 of 25 students selected for testing, the program enrollment effective date was incorrectly reported. Indication of Repeat Finding – This is a partial repeat of prior year finding 2024-001. Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are accurate and submitted to the NSLDS website within the required timeframe. Views of Responsible Officials – The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University will implement the following corrective actions to address the identified deficiencies: • Establishment of an internal audit function • Process review and cross-functional collaboration • Staffing and resource enhancements • Implementation of monitoring and control systems • Strengthening reporting protocols • Training and accountability measures By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.

Finding 2025-002 – N. Special Tests and Provisions – Return of Title IV Funds Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063 and 84.268) Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – A return of Title IV funds for a student was not completed within the required time frames. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements. Questioned Costs – None. Context – For 2 of 6 students selected for return of Title IV funds testing. Indication of Repeat Finding - This is a repeat of prior year finding 2024-003. Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames. Views of Responsible Officials – The University acknowledges Finding 2025-002 regarding noncompliance with federal requirements governing the timely return of Title IV funds. This finding, which represents a repeat of prior year Finding 2024-003, is taken with the utmost seriousness. The University is committed to implementing immediate and sustainable corrective actions to ensure full compliance with all applicable federal regulations. The University will implement the following corrective actions to address the identified deficiencies: • Establishment of an internal audit function • Strengthening interdepartmental communication • Implementation of technological solutions • Process standardization and internal controls • Staffing, training and accountability By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.

Finding 2025-003 – L. Reporting – Special Reports for Federal Funding Accountability and Transparency Act (“FFATA”) Information on Federal Program(s) – From Learning to Leading: Cultivating the Next Generation of Diverse Food and Agriculture Professionals (ALN 10.237) Criteria or Specific Requirement – Under the requirements of the Federal Funding Accountability and Transparency Act recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to System for Award Management (SAM.gov). The subaward/subcontract was subject to reporting under the Transparency Act and therefore any related subaward agreements/amendments/modifications were to be reported in SAM.gov no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The subaward agreement/amendment/modification was not submitted within the required time frame. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The subaward agreement was not submitted within the required time frames resulting in the University not being in compliance with special reporting requirements. Questioned Costs – None. Context – We tested the one subaward subject to FFATA requirements during the year. The University did not submit the subaward agreement within the required time frame on SAM.gov. Indication of Repeat Finding – No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls related to subrecipient reporting. Views of Responsible Officials – The University acknowledges Finding 2025-003 regarding noncompliance with reporting requirements under the Federal Funding Accountability and Transparency Act. Specifically, the University did not submit a first-tier subaward agreement/amendment/modification within the required timeframe to the System for Award Management (SAM.gov). The University will implement the following corrective actions to address the identified deficiencies: • Internal audit oversight and governance • Enhanced tracking and monitoring systems • Strengthening policies and procedures • Improved interdepartmental coordination • Training and capacity building • Pre-submission review and quality assurance By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.

Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs – None. Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website. Indication of Repeat Finding - This is a repeat of prior year finding 2023-002. Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken: 1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies. 2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance. 3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing. 4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner. 5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance. The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements. By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.

Finding 2024-002 – N. Special Tests and Provisions – Federal Perkins Loan Program Recordkeeping and Record Retention Information on Federal Program(s) – Student Financial Assistance Cluster (ALN 84.038) Criteria or Specific Requirement – Institutions are required to keep original paper promissory notes or original paper master promissory notes and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. After the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full and retain a copy for the prescribed period. An institution shall retain repayment records, including cancellation and deferment requests for at least three years from the date on which a loan is assigned to the secretary, canceled, or repaid. An institution shall retain disbursement and electronic authentication and signature records for each loan made using a master promissory note for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party servicer is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third party servicer’s most recent Title IV compliance audit. When an institution uses a third-party servicer for its Federal Perkins Loan Program, the institution must perform due diligence to ensure that the third party servicer is in compliance with the requirements for the functions the third party servicer is performing for the school. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Certain Federal Perkins Loan Program records selected for testing were missing a signed master promissory note, missing repayment schedules, missing documentation for the first disbursement, missing documentation for the last payment, or missing other documentation. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with the Federal Perkins Loan Program recordkeeping and record retention requirements. Questioned Costs – None. Context – For 1 of 40 Federal Perkins Loan Program records selected for testing, we noted that 1 record was missing a signed master promissory note and a repayment schedule. Indication of Repeat Finding - This is a repeat of prior year finding 2023-005. Recommendation – We recommend that the University enhance its procedures and internal controls related to Federal Perkins Loan Program recordkeeping and record retention. Views of Responsible Officials – The University acknowledges this finding and during its liquidation of the Federal Perkins Loan Program completed the buyback of certain loans for which the University was not able to provide adequate documentation to assign these loans to the Department of Education. Subsequent to June 30, 2024, the University has completed the following steps in the closeout of its Federal Perkins Loan Program: 1. Notified the Department of Education of the intent to liquidate. 2. Assigned outstanding Perkins loans to the Department of Education and updated NSLDS throughout the assignment process. 3. Purchased loans not qualifying for assignment and submitted cash on hand (Intent and Closeout Form Phase 3 in COD) 4. Remitted the federal share to the Department 5. Submitted final FISAP data (Intent to Closeout Form Phase 4 in COD) The final remaining step for the University to complete closeout of its Federal Perkins Loan Program is to submit a Perkins closeout audit to the Department. This will be submitted as part of the Single Audit for the year ended June 30, 2025, which is due March 31, 2026.

Finding 2024-003 – N. Special Tests and Provisions – Return of Title IV Funds Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268 and 84.379) Criteria or Specific Requirement – Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – A return of Title IV funds for a student was not completed within the required time frames. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – A return of Title IV funds was not completed within the required time frames resulting in the University not being in compliance with return of Title IV funds requirements. Questioned Costs – None. Context – For 1 of 3 students selected for return of Title IV funds testing. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds within the required time frames. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken: 1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies. 2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines. 3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds. By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements.

Finding 2024-004 – E. Eligibility – Over award of Title IV Funds Information on Federal Program(s) – Student Financial Assistance Cluster (ALN 84.268) Criteria or Specific Requirement – Student financial assistance awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – A student was awarded total aid in excess of the student’s cost of attendance. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – A student received total aid in excess of the student’s cost of attendance resulting in the University not being in compliance with eligibility requirements. Questioned Costs – Known questioned costs were $2,742 which were specific to 1 of 25 student selected for eligibility testing who received total aid in excess of the student’s cost of attendance. Context – For 1 of 25 students selected for eligibility testing. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls related to award of student financial assistance awards to prevent total aid from being award in excess of the student’s cost of attendance. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal financial aid regulations. The following steps will be undertaken: 1. Strengthen Financial Aid Coordination: The Financial Aid team will enhance coordination among various programs and between federal and non-federal aid sources to ensure that total aid awarded does not exceed a student’s financial need or cost of attendance. This aligns with federal regulations requiring institutions to prevent over awards by adjusting aid packages accordingly. 2. Implement Advanced Technological Solutions: The University will collaborate with technology support teams to develop data platforms and scripts that monitor and control award amounts, ensuring they do not surpass students’ cost of attendance. This proactive approach will aid in preventing future over award situations. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal financial aid regulations and to uphold the integrity of its financial aid programs. By implementing these measures, the University aims to rectify the identified over award issue and prevent similar occurrences in the future, thereby maintaining compliance with Title IV funding requirements.

Finding 2024-005 – L. Reporting – Financial Reporting Information on Federal Program(s) – Student Financial Assistance Cluster (ALN 84.268) Criteria or Specific Requirement – Institutions submit Federal Direct Student Loans, Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education Grants, and Iraq and Afghanistan Service Grant origination records and disbursement records to the Common Origination and Disbursement (“COD”) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 86, Number 119, June 24, 2021). The disbursement record reports the actual disbursement date and the amount of the disbursement. U.S. Department of Education processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the origination and disbursement data, the auditor should be most concerned with the data U.S. Department of Education has categorized as accepted or accepted with corrections. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – For a disbursement of Federal Direct Student Loans program funds, the University did not submit the origination and disbursement records to the COD system within the required timeframes. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University did not submit the origination and disbursement records to the COD system within the required timeframes resulting in the University not being in compliance with the financial reporting requirements. Questioned Costs – None. Context – For 1 of 25 students selected for COD reporting testing. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls related to the submission of origination and disbursement records to the COD system. Views of Responsible Officials – The University acknowledges this finding and is committed to immediate corrective measures to ensure compliance with federal regulations. The following actions will be undertaken: 1. Enhance Procedures and Internal Controls: The University will strengthen its procedures and internal controls related to the submission of origination and disbursement records to the COD system. This includes implementing stricter monitoring mechanisms to ensure all records are submitted within the required timeframes. 2. Implement Advanced Technology Solutions: To improve the efficiency and accuracy of financial reporting, the University will adopt advanced technology solutions. These tools will facilitate timely and accurate submission of required data to the COD system. The newly established internal audit team will oversee the implementation and management of these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal origination and disbursement requirements. By taking these steps, the University aims to rectify the identified deficiency and prevent future occurrences, thereby maintaining the integrity of its financial reporting processes.

Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.

Identification of the Federal Program: Student Financial Assistance Cluster (“SFA Cluster”) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (“NSLDS”) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student’s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 14 students selected for transfer monitoring testing, the University did not wait 7 days after it informed NSLDS about a transfer student before disbursing Title IV aid to those students. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions – Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: Exceptions were noted for 14 of 24 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2022-003. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies. In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department. Management and implementation of current corrective plans are critical to the compliance efforts of the University: The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle. In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved.

Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting – Status Change – Campus Level: Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who withdrew during the year. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat of prior year finding 2022-007. Recommendation: We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. Management and implementation of current corrective plans are critical to the compliance efforts of the University: As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team. As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe.

Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (“HEERF”) Historically Black Colleges and Universities (“HBCUs”) (Assistance Listing #84.425J) and HEERF Supplemental Support under the American Rescue Plan (Assistance Listing #84.425T) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – There are three components to reporting for the Higher Education Emergency Relief Fund (“HEERF”): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report. Condition: The University did not post 2 quarterly reports selected for testing for the year ended June 30, 2023. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with the quarterly reporting requirement of the HEERF program. Questioned Costs: None. Context: For 2 of 3 quarterly reports selected for testing the University did not publicly post the reports to the University’s website. Identification as a Repeat Finding: This is a repeat of prior year finding 2022-005. Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that the quarterly reports are prepared and posted within the required time frames. Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies. Management and implementation of current corrective plans are critical to the compliance efforts of the University: To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University’s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be overseen by the Assistant Provost for Sponsored Programs, who will function as a neutral third party. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. During the prior reporting periods under review, the University was in the process of submitting and seeking approval of a no-cost extension. During this same period that is under review, the University closed out the current “HEERF” grant and was awarded a “no-cost” extension from the Department of Education. In the University’s attempt to secure a “no-cost” extension from the Department of Education, the reporting schedules under review were developed but not posted to the University’s website as required. The oversight of the reporting process will be a key performance indicator for the internal audit team as we prepare for the “no-cost” extension phase of the grant.

Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements: Institutions are required to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement. Condition: The University did not meet the low default rate requirement and did not wait 30 days before disbursing funds to 2 first time borrowers selected for testing. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with the requirements of Disbursements to or on Behalf of Students. Questioned Costs: None. Context: Exceptions were noted for 2 of 25 students selected for general disbursement testing. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhances its procedures and internal controls over the compliance requirements of Special Tests and Provisions – Disbursements To or On Behalf of Students – General Disbursements. Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the compliance requirements of General Disbursements. The rule requiring the University to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement must be adhered to and reviewed by the Office of Financial Aid with oversight from the new internal audit team. This will be a critical reporting area for both the Office of Financial Aid and the internal audit team.

Identification of the Federal Program: Federal Perkins Loan Program (Assistance Listing #: 84.038) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Perkins Loan Recordkeeping and Record Retention: Institutions are required to keep original paper promissory notes or original paper master promissory notes and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. After the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full and retain a copy for the prescribed period. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third party servicer is in compliance with the requirements for the functions the third party servicer is performing for the school. Condition: For 2 students selected for testing, the University was unable to provide evidence that the student’s Perkins Loan repayment schedule was retained as required. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the Perkins Loan Recordkeeping and Record Retention requirements. Questioned Costs: None. Context: For 2 of 40 students selected for Perkins Loan Recordkeeping and Record retention testing, an exception was noted. Identification as a Repeat Finding: This is a repeat or prior year finding 2022-008. Recommendation: We recommend that the University enhances its procedures and internal controls to ensure compliance with the special reporting requirements. Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. The University’s inability to provide evidence that a student’s Perkins Loan repayment schedule and another student’s Perkins Loan file were retained as required will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements.

Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Reporting: Institutions participating in the campus-based programs of the SFA Cluster are required to complete and submit a Fiscal Operations Report and Application to Participate (the “FISAP”) annually. As applicable, amounts reported on each type of report should agree to financial information records that support the audited financial statements and the audited schedule of expenditures of federal awards. Condition: Special Reporting: The University completed and submitted its FISAP within the required time frames, however, certain amounts included on the FISAP could not be reconciled back to supporting documentation. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the special reporting requirements. Questioned Costs: None. Context: For 1 of 1 report selected for Special Reporting testing. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhances its procedures and internal controls to ensure compliance with the special reporting requirements. Views of Responsible Officials: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department. The University’s failure to reconcile the Fiscal Operations Report and Application to Participate to supporting documentation will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed and/or modified as necessary. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements.

Identification of the Federal Program: Student Financial Assistance Cluster (?SFA Cluster?) (Assistance Listing #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student?s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 3 students selected for transfer monitoring testing, the University was unable to provide support that the required transfer monitoring procedures were performed. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: Exceptions were noted for 3 of 15 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University?s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeat finding, the University?s corrective action plan is being implemented immediately?Spring 2023. An internal review will be performed using Spring 2023 data with the assistance of the Director of Financial Aid, Director of Transfer Students and a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb).

Identification of the Federal Program: Federal Direct Loan Program (CFDA #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students: For students that received disbursements of Direct Loans or Federal Perkins Loans, institutions must notify the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution. For first time borrowers, the University cannot distribute funds to students before the passage of 30 days after the student?s first day of classes. Condition: The University notified 2 students/parents of their loan disbursements more than 30 days before crediting the student?s account. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students. Questioned Costs: None. Context: Exceptions were noted for 2 of 25 students selected for notification testing. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhances its internal controls over the compliance requirements of Special Tests and Provisions ? Disbursements To or On Behalf of Students. Views of Responsible Officials: The Financial Aid division has revised its compliance process to ensure the effective administrative and internal control oversight of the notification of the Direct Loan disbursements. As a part of this revised compliance process, students receiving financial aid while attending one or more other institutions will be ?singled out? for a detail review in accordance with the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. The Director of Financial Aid will perform periodic reviews to ensure the new process is being effectively executed in a timely and accurate manner. An internal review will be performed Spring 2023 with the Director of Financial Aid, Data Coordinator and neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb).

Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (Assistance Listing #84.425E), HEERF Institutional Portion (Assistance Listing #84.425F) and HEERF Historically Black Colleges and Universities (?HBCUs?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? There are three components to reporting for the Higher Education Emergency Relief Fund (?HEERF?): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report. Condition: The University did not submit certain quarterly reports and submitted its annual report subsequent to the required deadline for the year ended June 30, 2022. Certain information submitted to the funding agency within financial reports was not accurate and not appropriately reconciled to the University?s records. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with the quarterly reporting and annual reporting requirements of the HEERF program. Questioned Costs: None. Context: For 2 of 3 quarterly reports selected for testing and 1 of 1 annual report selected for testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-004. Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that they are posted within the required time frames. Views of Responsible Officials: To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University?s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be internally by the Assistant Provost for sponsored program, who will function as a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record on a monthly basis). The University Controller in coordination with the Financial Aid Director will prepare required reports and submit to the CFO for review. Once the CFO has reviewed, and approved, a service request will be submitted to the University IT to post the information to the website. The CIO has identified a technician with the necessary skill set to update the website until a permanent web-master can be identified (currently being conducted through contractual services). Once the website has been updated the service ticket will be updated and closed.

Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (?Student Aid Portion?) (Assistance Listing #84.425E) and HEERF Historically Black Colleges and Universities (?HBCUs Aid Portion?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management: In addition to these basic cash management principles, for Coronavirus Response and Relief Supplemental Appropriations Act (?CRRSAA?) HEERF II and America Rescue Plan (?ARP?) HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (AL #84.425E) should be disbursed within 15 calendar days of the drawdown from the U.S. Department U.S. Department of Education?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the draw down from G5. Condition: Student Aid Portion: For 1 period of time in excess of 15 calendar days during the year ended June 30, 2022, the University had cumulative drawn down funds that exceeded the cumulative disbursements. HBCUs Aid Portion: For 1 period of time in excess of 3 calendar days during the year ended June 30, 2022, the University had cumulative drawn down funds that exceeded the cumulative disbursements. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the cash management requirements of the Education Stabilization Fund program. Questioned Costs: None. Context: Refer to the Condition section of this finding for the context. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: We recommend that the University enhances its internal controls to ensure compliance with the cash management requirements of the Education Stabilization Fund program. Views of Responsible Officials: To enhance the internal controls to ensure compliance with the cash management requirements of the Education Stabilization Fund program, the University will immediately implement a draw down/disbursement reconciliation plan. Our compliance committee will review each draw down, to ensure that disbursements are recorded in accordance with the Student Aid Portion and Institutional Aid Portion policies. The review of this process will be recorded and memorialized for the record.

Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Status Change: Institutions are required to update students? statuses on the NSLDS website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit timely notification to the NSLDS website for 1 student selected for testing who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat of prior year finding 2021-003. Recommendation: We recommend that the University enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination with the Information Technology Division will develop a ?flag based? process to capture and review all enrollment status changes on a monthly basis. This new reporting process will enhance the Registrar?s ability to review and accurately submit timely notifications to the National Student Loan Data System (?NSLDS?). These monthly reviews will be recorded and memorialized for the record.

Identification of the Federal Program: Federal Perkins Loan Program (Assistance Listing #: 84.038) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Perkins Loan Recordkeeping and Record Retention: Institutions are required to keep original paper promissory notes or original paper master promissory notes and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. After the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full and retain a copy for the prescribed period. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third party servicer is in compliance with the requirements for the functions the third party servicer is performing for the school. Condition: For 6 students selected for testing, the University was unable to provide evidence that the student?s Perkins Loan repayment schedule was retained as required. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the Perkins Loan Recordkeeping and Record Retention requirements. Questioned Costs: None. Context: For 6 of 25 students selected for Perkins Loan Recordkeeping and Record retention testing, an exception was noted. Identification as a Repeat Finding: This is a repeat or prior year finding 2021-007. Recommendation: We recommend that the University enhances its internal controls to ensure compliance with the special reporting requirements. Views of Responsible Officials: In our effort to enhance our ability to access older Perkins Loan records, we will engage our information technology consultants to research our information collection system. Currently our ability to access older Perkins Loan records is restricted due to system constraints. The findings from this engagement will be recorded and memorialized for the record.

FINDING 2021-002 Identification of the Federal Program: Student Financial Assistance Cluster (?SFA Cluster?) (Assistance Listing #: 84.007, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student?s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 2 students selected for transfer monitoring testing, the University was unable to provide support that the required transfer monitoring procedures were performed. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: For 2 of 22 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2020-003. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The University has made the necessary changes to the staff and enabled all of the financial aid counselors with the necessary access/ability to generate the information and update the system. This important cross training and sharing of knowledge will eliminate the challenge created by one staff person being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. All the findings noted occurred in the Fall 2020 term, the University? corrective action was implemented early Spring 2020. An internal review was performed Spring 2020 transfer monitoring did not identify similar errors. The corrective action implemented in Spring 2020 appears to have addressed the issue.

FINDING 2021-003 Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ? Status Change: Institutions are required to update students? statuses on the NSLDS website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit timely notification to the NSLDS website for 4 students selected for testing who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 4 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: We recommend that the University enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: To ensure effective administrative and internal control oversight of enrollment reporting requirements, the staff in the Registrar?s office has revised its compliance processes.

FINDING 2021-004 Identification of the Federal Program: COVID-19 Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (Assistance Listing #84.425E) and HEERF Historically Black Colleges and Universities (?HBCUs?) (Assistance Listing #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? There are three components to reporting for the Higher Education Emergency Relief Fund (?HEERF?): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and a(3) subprograms (Quarterly Reporting Form) within 10 days of each quarter end, as applicable; and 3) the annual report. Condition: The University is not in compliance with certain Reporting requirements. Certain information submitted to the funding agency within financial reports was not accurate and not appropriately reconciled to the University?s records. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with the quarterly reporting and annual reporting requirements of the HEERF program. Questioned Costs: None. Context: Refer to the Condition section above. Identification as a Repeat Finding: This is a repeat of prior year finding 2020-004. Recommendation: We recommend that the University enhance its procedures and internal controls over the HEERF reporting requirements to ensure that they are posted within the required time frames. Views of Responsible Officials: To ensure future reporting is posted timely, and in the required format, the University Controller, Financial Aid Director and CFO will periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. The University Controller in coordination with the Financial Aid Director will prepare required reports and submit to the CFO for review. Once the CFO has reviewed, and approved, a service request will be submitted to the University IT to post the information to the website. The CIO has identified a technician with the necessary skill set to update the website until a permanent webmaster can be identified. Once the website has been updated the service ticket will be updated and closed.

FINDING 2021-005 Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Eligibility: Among other eligibility requirements, institutions are required to: 1) calculate cost of attendance based on the student?s enrollment status (full-time, half-time, less than half-time, etc.), 2) Estimate student loan awards based on need and expected family contribution and 3) determine whether the student was eligible Condition: For 1 student, the University packaged the federal aid incorrectly which resulted in the student exceeding his/her loan limit. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with eligibility requirements. Questioned Costs: Below reportable threshold. Context: For 1 of 40 students selected for eligibility testing. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhances its internal controls to ensure compliance with the eligibility requirements. Views of Responsible Officials: The Financial Aid process utilizes the aid packaging module in Banner, which awards aid based on the classification reflected on the FAFSA. The Financial Aid counselors are responsible for reviewing the student?s earned credits hours and adjusting the aid awards prior to authorization. Unfortunately, there are instances where the FAFSA classification does not match the student?s classification based on earned credit hours, and the accounts were not properly reviewed. The accounts identified were adjusted. In fiscal year 2020-21, the review process was modified to include a periodic review, using sample populations, by the Director of Financial Aid to ensure the aid is awarded correctly. In addition, the Financial Aid staff will receive onsite training in Spring 2021.

FINDING 2021-006 Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.007, 84.033, 84.038, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Reporting: Institutions participating in the campus-based programs of the SFA Cluster are required to complete and submit a Fiscal Operations Report and Application to Participate (the ?FISAP?) annually. As applicable, amounts reported on each type of report should agree to financial information records that support the audited financial statements and the audited schedule of expenditures of federal awards. Condition: Special Reporting: Though the University completed and submitted its FISAP within the required time frames, certain amounts included on the FISAP could not be reconciled back to supporting documentation. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the special reporting requirements. Questioned Costs: None. Context: For 1 of 1 report selected for Special Reporting testing. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhances its internal controls to ensure compliance with the special reporting requirements. Views of Responsible Officials: Effective 2020-21 the processes will be modified to require that once the FISAP is completed by the Director of Financial Aid, it will be reviewed by the University?s Controller, and approved by the University?s CFO prior to submission.

FINDING 2021-007 Identification of the Federal Program: SFA Cluster (Assistance Listing #: 84.038) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Perkins Loan Recordkeeping and Record Retention: Institutions are required to keep original paper promissory notes or original paper master promissory notes and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. After the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full and retain a copy for the prescribed period. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third party servicer is in compliance with the requirements for the functions the third party servicer is performing for the school. Condition: For 1 student selected for testing, the University was unable to provide evidence that the student?s Perkins Loan repayment schedule was retained as required. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the Perkins Loan Recordkeeping and Record Retention requirements. Questioned Costs: None. Context: For 1 of 10 students selected for Perkins Loan Recordkeeping and Record retention testing. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhances its internal controls to ensure compliance with the special reporting requirements. Views of Responsible Officials: Effective 2020-21 the processes will be modified to require that the University performs their own sample testing of Perkin?s loans in order to ensure that the third-party servicer is in compliance with the Perkins Loan requirements.

FINDING 2020-002 Identification of the Federal Program: Federal Pell Grant Program (?Pell Grant?) (CFDA #84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility ? Federal Pell Grants ? In determining the Pell Grant award for each student, an institution is required to determine the student?s enrollment status (full-time, three-quarter time, half-time, or less than-half-time) in accordance with the requirements under definitions of those terms in 34 CFR 668.2. Condition: The University did not properly determine a student?s enrollment status, resulting in a student who was enrolled three-quarter time receiving a Pell Grant award equivalent to being enrolled half-time. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the required federal guidelines over Pell Grants awards and the student received less Pell Grant awards than was eligible to receive. Questioned Costs: None. Context: For 1 of 40 students selected for Eligibility testing. Identification as a Repeat Finding: This is not a repeat of a prior year finding. Recommendation: We recommend that the University enhances its procedures over the enrollment status of Pell Grant recipients. Views of Responsible Officials: A periodic update to the federal Pell calculations and award maintenance in the University?s ERP system caused a ?glitch? in the system calculation that resulted in the student being under-awarded. The Financial Aid staff will run processes to update the system monthly, and report on updates in the award amount. In addition, the Director of Financial Aid will be notified when process has been completed to ensure the process is being done timely and accurately.

FINDING 2020-003 Identification of the Federal Program: Student Financial Assistance Cluster (?SFA Cluster?) (CFDA #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student?s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: For 5 students selected for transfer monitoring testing, the University was unable to provide support that the required transfer monitoring procedures were performed. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements to or on Behalf of Students for transfer students. Questioned Costs: None. Context: For 5 of 29 students selected for transfer monitoring testing. Identification as a Repeat Finding: This is a repeat of prior year finding 2019-002. Recommendation: We recommend that the University enhance its procedures and internal controls over transfer monitoring requirements of Title IV aid to ensure compliance. Views of Responsible Officials: The staff person assigned the responsibility for initiating the process, generating the information and updating the system was to perform the functions on a weekly basis. The University has made the necessary changes to the staff and enabled all of the financial aid counselors with the access/ability to generate the information and update the system. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. All the findings noted occurred in the Fall 2020 term, the University? corrective action was implemented early Spring 2020. An internal review was performed Spring 2020 transfer monitoring did not identify similar errors. The corrective action implemented in Spring 2020 appears to have addressed the issue.

FINDING 2020-004 Identification of the Federal Program: Higher Education Emergency Relief Fund (?HEERF?) Institutional Portion (CFDA #84.425F) and HEERF Historically Black Colleges and Universities (?HBCUs?) (CFDA #84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? Special Reporting ? Quarterly Budget and Expenditure Reporting Under CARES Act Sections 18004(a)(1) Institutional Portion and 18004(a)(2): Institutions that were awarded HEERF Institutional Portion and HEERF HBCUs funds must be conspicuously post on the institution?s primary website on the same page the reports of the institution?s activities as to the emergency financial aid grants to students made with funds from the institution?s allocation under Section 18004(a)(1) of the CARES Act (Student Aid Portion) are posted. New, separate reporting forms must be posted covering each quarterly reporting period concluding after either (1) posting the quarterly report ending September 30, 2022, or (2) when an institution has expended and liquidated all (a)(1) Institutional Portion and (a)(2) funds and checks the ?final report? box. Institutions must post this quarterly report form no later than 10 days after the end of each calendar quarter. Condition: The University did not post any of the required quarterly reports under CARES Act Sections 18004(a)(1) Institutional Portion and 18004(a)(2) within the required time frames. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with the quarterly reporting requirements of the HEERF program. Questioned Costs: None. Context: Refer to the Condition section above. Identification as a Repeat Finding: This is not a repeat of a prior year finding. Recommendation: We recommend that the University enhance its procedures and internal controls over the quarterly HEERF reporting requirements (CARES Act Sections 18004(a)(1) Institutional Portion and 18004(a)(2)) to ensure that they are posted within the required time frames. Views of Responsible Officials: The quarterly reporting requirements changed in October 2020, after the end of the fiscal year. The June 2020 and September 2020 reports included a summary of the HEERF Institutional Portion spending. The HEERF HBCUs funds were unspent until the December 2020 reporting period. The reporting was prepared in the revised format but not posted to the University website due to a vacancy in the webmaster position. To ensure future reporting is posted timely, and in the required format, the University Controller, Financial Aid Director and CFO will periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. The University Controller will prepare required reports and submit to the CFO for review. Once the CFO has reviewed, and approved, a service request will be submitted to the University IT to post the information to the website. The CIO has identified a technician with the necessary skill set to update the website until a permanent webmaster can be identified. Once the website has been updated the service ticket will be updated and closed.

FINDING 2019-002 Identification of the Federal Program: SFA Cluster (CFDA #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements To or On Behalf of Students ? Transfer Monitoring: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert from NSLDS during the 7-day period or if it obtains the student?s financial aid history by accessing the NSLDS Financial Aid Professional website. Condition: The University did not wait 7 days before disbursing funds to 1 transfer student. For 16 students selected for transfer monitoring testing, the University was unable to provide support that the required transfer monitoring procedures were performed. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with the requirements of Special Tests and Provisions ? Disbursements To or On Behalf of Students for transfer students. Questioned Costs: None. Context: For 1 of 30 students selected for transfer monitoring testing the University did not wait 7 days before disbursing funds as required. For 16 of 30 selected for transfer monitoring testing, the University was unable to provide support that transfer monitoring procedures were performed. Identification as a Repeat Finding: This is a repeat of prior year finding 2018-002. Recommendation: We recommend that the University enhance its internal controls over disbursement requirements of federal student aid to ensure compliance with the return of Title IV Funds requirement. Views of Responsible Officials: The staff assigned the responsibility for initiating the process, generating the information and updating the system was to perform the functions on a weekly basis. Unfortunately, the duties were not performed as instructed/required. The University has made the necessary changes to the staff and enabled all of the financial aid counselors with the access/ability to generate the information and update the system. In addition, the Director of Financial Aid receive alerts when the process has been completed, and performs periodic reviews, using sample populations, to ensure the process is being done timely and accurately.

FINDING 2019-003 Identification of the Federal Program: SFA Cluster (CFDA #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Eligibility: Among other eligibility requirements, institutions are required to: 1) calculate cost of attendance based on the student?s enrollment status (full-time, half-time, less than half-time, etc.), 2) Estimate student loan awards based on need and expected family contribution and 3) determine whether the student was eligible Condition: For 3 students, the University packaged the federal aid incorrectly which resulted in the student exceeding his/her loan limit. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University was not in compliance with eligibility requirements. Questioned Costs: Below reportable threshold. Context: For 3 of 40 students selected for eligibility testing. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhances its internal controls to ensure compliance with the eligibility requirements. Views of Responsible Officials: The Financial Aid process utilizes the aid packaging module in Banner, which awards aid based on the classification reflected on the FAFSA. The Financial Aid counselors are responsible for reviewing the student?s earned credits hours and adjusting the aid awards prior to authorization. Unfortunately, there are instances where the FAFSA classification does not match the student?s classification based on earned credit hours, and the accounts were not properly reviewed. The accounts identified were adjusted, and the excess funds totaling $2,968 were returned January 2020 before the 18-19 aid year closed. In fiscal year 2019-20, the review process was modified to include a periodic review, using sample populations, by the Director of Financial Aid to ensure the aid is awarded correctly. In addition, the Financial Aid staff will receive onsite training in Spring 2020.

FINDING 2019-004 Identification of the Federal Program: SFA Cluster (CFDA #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students - Credit Balances: An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date the school issued the check. Condition: The University did not refund credit balances to 1 student selected for testing within the required timeframe. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the required federal guidelines over credit balances from student financial assistance. Questioned Costs: None. Context: For 1 of 40 students selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe. Identification as a Repeat Finding: This is a repeat of prior year finding 2018-006. Recommendation: We recommend that the University enhance its procedures over the refunding of credit balances created by federal awards within the required time frame. Views of Responsible Officials: During fiscal year 2019 the staff in Financial Aid and the Treasurer?s Office established a schedule for Financial Aid to authorize aid that ensured the Treasurer?s Office has sufficient time to review and process within the required 14 calendar days. This resulted in a significant reduction in the instances of non-compliance from 18 of 40 in 2018, to 1 of 40 in 2019. The one instance in 2019 had special circumstances that were not previously identified. As a result, the process was modified to ensure the accounts with special circumstances can be identified and the necessary adjustments made to ensure all refundable amounts are issued within 14 calendar days.

FINDING 2019-005 Identification of the Federal Program: SFA Cluster (CFDA #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Enrollment Reporting ? Status Change: Institutions are required to update students? statuses on the NSLDS website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit timely notification to the NSLDS website for 5 students selected for testing who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Cause: Administrative and internal control oversight. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 5 of 40 students sampled whose status changed during the fiscal year, the University did not submit a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat of prior year finding 2018-007. Recommendation: We recommend that the University enhance its internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: The staff in the Registrar?s Office, which has the responsibility for reporting status changes through the National Clearinghouse, revised its processes late in fiscal year 2019. Unfortunately, during the transition to new process there were a few instances of errors/rejects that went undetected/unresolved. The Registrar?s Office, in conjunction with the Office of Financial Aid, will continue to perform periodic reviews, using sample populations, to ensure the information reported through the National Clearinghouse is reflected on the National Student Loan Data System (?NSLDS?) accurately and timely.

FINDING 2019-006 Identification of the Federal Program: SFA Cluster (CFDA #: 84.007, 84.033, 84.063, 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Gramm-Leach-Bliley Act ? Student Information Security: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department of Education or otherwise obtained in support of the administration of the federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). As part of this act, institutions are required to designate an individual to coordinate the information security program; perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) and documented safeguards for each of the risks identified by the institution. Condition: The University did not designate an individual to coordinate the information security program; did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) and did not formally document safeguards for risks as required. Cause: Administrative oversight in the internal controls over compliance with the Gramm-Leach-Bliley Act requirements. Effect or Potential Effect: The University is not in compliance with the Gramm-Leach-Bliley Act requirements. Questioned Costs: None. Context: Refer to the Condition section above. Identification as a Repeat Finding: This is not a repeat of a prior year finding. Recommendation: We recommend that the University enhance its internal controls over the Gramm-Leach-Bliley Act requirements by designating an individual to coordinate the information security program; performing a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) and formally documenting the safeguards for each of the risks identified by the University. Views of Responsible Officials: The University will seek will employ a security officer Fall 2020 to serve as the designated coordinator of the information security program. In addition, the University will establish an Information Security Team(?IST?), whose function will be to develop the vision, objectives, and goals for the information security program, as well as develop information security policies and processes that ensure the review and implementation of those policies. The IST will include the CEO, CIO, CFO, Facilities Director, Financial Aid Director, HR Director, the Registrar, Accreditation Liaison, or a designee from each area, and others identified as needed. A risk assessment was performed in 2019 that covered network and software design, as well as information processing, storage, transmission and disposal; and detecting, preventing and responding to attacks, intrusions, or other systems failures. While the assessment did not include employee training and management, the University does require employees to complete a cybersecurity awareness training annually - the training curriculum is provided by the SANS Institute. An assessment of employee training and management will be conducted in Fall 2020. Safeguards implemented to address risks identified in the security assessments will be shared with the Information Security Team and minutes of those meetings will be used as documentation. Recommendations to adjust the information security program in light of the results of testing and monitoring will also be recorded.

FINDING 2019-007 Identification of the Federal Program: Payments to 1890 Land-Grant Colleges and Tuskegee University (CFDA #: 10.205) (?1890 Land-Grant Award?) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Reporting: In accordance with the 1890 Land-Grant Award agreements, each institution shall submit a progress report annually for each eligible project. All progress reports from institutions are based on the federal fiscal year and should be submitted by March 1st for the preceding fiscal year. Condition: For 1 progress reports selected for testing, the University did not submit the report within the required time frames. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the Reporting compliance requirements of its 1890 Land-Grant Award. Questioned Costs: None. Context: For 1 of 4 reports selected for testing. Identification as a Repeat Finding: This is not a repeat of a prior year finding. Recommendation: We recommend that the University enhances its procedures over compliance and processes over Reporting. Views of Responsible Officials: To ensure future reporting deadlines are met, the submission process will be revised to require reports be submitted to the 1890 Executive Director (?1890 ED?) two (2) weeks prior to the agency reporting deadline. Once the 1890 ED has reviewed, and approved the report, it will be returned to the originator for submission prior to the submission deadline. Once the report has been submitted, the confirmation will be sent to the 1890 ED and other designated staff for recordkeeping.

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