Morehouse College

Eligibility Federal Program Student Financial Assistance Cluster Assistance Listing Number 84.033 Federal Work StudyFederal Agency U.S. Department of Education Federal Award Years July 1, 2024 to June 30, 2025 Criteria or Requirement CFR §675.9 provides student eligibility requirements, stating that a student at an institution of higher education is eligible to receive part-time employment under the Federal Work Study (FWS) program for an award year if the student (a) meets the relevant eligibility requirements contained in 34 CFR 668.32; (b) is enrolled or accepted for enrollment as an undergraduate, graduate or professional student at the institution; and (c) has financial need as determined in accordance with part F of title IV of the HEA. The financial need determination relies upon the assessment of a cost of attendance which is established under the Higher Education Act, Section 472. Condition and Context During our test work over eligibility for 40 students with total aid received from the student financial assistance cluster of $1,250,644, we selected a student receiving FWS funding for whom the cost of attendance had been increased due to the student’s involvement in the FWS program by $2,810. While the cost of attendance should not have been increased for this purpose, the student did not receive aid in excess of their financial need as a result of this increase in cost of attendance. Cause and Potential Effect The cost of attendance was increased as a result of a misunderstanding related to certain guidance relevant only to the Federal Work Study program. Questioned Cost There are no known questioned cost associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat Finding in the Immediately Prior Audit This is not a repeat finding in the immediately prior year audit. Recommendation We recommend that the College reconsider their process related to the assessment of cost of attendance for students receiving Federal Work Study funding to ensure each student has financial need as determined in accordance with part F of title IV of the HEA.View of Responsible Officials Management agrees with the finding. To address the finding and ensure compliance with federal regulations governing the Federal Work Study program, the Office of Financial Aid will clarify the policy and adjust the award process to ensure that aid adjustments remain compliant with federal need-analysis requirements.

Finding No. 2024-001 Enrollment Reporting Federal Program Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans Federal Agency U.S. Department of Education Federal Award Years October 1, 2022 to September 30, 2023 October 1, 2023 to September 30, 2024 Criteria or Requirement Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34CFR 690.83(b)(2); FFEL, 34CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). Condition and Context During our test work, we selected a sample of 40 students that had enrollment status changes during fiscal year 2024. Within our sample, we identified 4 instances where the students’ enrollment status was not properly communicated to National Student Loan Data System (NSLDS). These instances involved students who provided late change in status information to the College outside of normal reporting period. Cause and Potential Effect Noncompliance due to no control in place to identify late submissions of status changes and ensure that these changes are properly communicated to the NSLDS. This lack of control could result in inaccurate or delayed reporting of student status changes to the NSLDS, potentially affecting loan servicing and compliance with federal regulations. Questioned Cost There were no questioned cost associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat Finding in the Immediately Prior Audit This is not a repeat finding in the immediately prior year audit. Recommendation We recommend that the College strengthen its processes and controls to ensure reporting of enrollment status changes via the NSLDS and that additional supervisory review procedures be implemented to monitor reporting of these status changes. View of Responsible Officials Management agrees with the finding. An enhanced internal control process will be implemented by the Registrar Office of Records and Registration Department to ensure that all student enrollment status changes are reported via NSLDS.

Finding No. 2023-001 Reporting Federal Program Student Financial Assistance Cluster AL No. 84.268 Federal Direct Student Loans Federal Agency U.S. Department of Education Federal Award Years October 1, 2021 to September 30, 2022 October 1, 2022 to September 30, 2023 Criteria or Requirement Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. Condition and Context During our testwork, we selected a sample of 40 students that were awarded federal loans during fiscal year 2023. Within our sample, we noted 10 out of 160 instances across 9 students in which the College did notify the student, no earlier than 30 days before, and no later than 30 days, after crediting the student’s account with Direct Loan as required. Cause and Potential Effect Noncompliance due to no control in place to ensure that all notifications of loan disbursements are submitted promptly. The federal loan disbursement notification reporting exceptions are systemic in nature. Questioned Cost There were no questioned cost associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat Finding in the Immediately Prior Audit This is not a repeat finding in the immediately prior year audit. Recommendation We recommend that the College strengthen its processes and controls to ensure timely reporting of loan disbursement notifications to students and that additional supervisory review procedures be implemented to monitor timely reporting of these notifications. View of Responsible Officials Management agrees with the finding. An enhanced internal control process will be implemented by the Office of Financial Aid and Scholarship Department to ensure that all disbursement notifications are reported to the student within the 30 day reporting requirement

Finding No. 2022-001 Reporting Federal Program Student Financial Assistance Cluster AL No. 84.268 Federal Direct Student Loans 84.063 Federal Agency U.S. Department of Education Federal Award Years October 1, 2020 to September 30, 2021 October 1, 2021 to September 30, 2022 Criteria or Requirement Under the Federal Register (82 FR 29061), all schools receiving federal direct student loans submit payment data to the Department through the Common Origination and Disbursement (COD) System. Institutions must report student payment data within 15 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, biweekly or weekly or may set up their own system to ensure that changes are reported in a timely manner. Condition and Context During our testwork, we selected a sample of 40 students that were awarded federal loans during fiscal year 2022. Within our sample, we noted 5 instances across 4 students in which the College did not submit the payment data to the COD within 15 days as required. Cause and Potential Effect Noncompliance due to the controls to ensure that all reports of loan funding are submitted on a timely basis not being operated effectively. The federal loan reporting exceptions are systemic in nature. Questioned Cost There were no questioned cost associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat Finding in the Immediately Prior Audit This is not a repeat finding in the immediately prior year audit. Recommendation We recommend that the College strengthen its processes and controls to ensure timely reporting of loan funding to students and that additional supervisory review procedures be implemented to monitor timely reporting of these disbursements. View of Responsible Officials Management agrees with the finding. An enhanced internal control process will be implemented by the Office of Financial Aid and Scholarship Department to ensure that all disbursement records are reported to the COD within the required 15-day reporting requirement.

Finding No. 2020 001 Reporting Federal Program Student Financial Assistance Cluster CFDA No. 84.063 ? Federal Pell Grant Program Federal Agency U.S. Department of Education Federal Award Years October 1, 2018 to September 30, 2019 October 1, 2019 to September 30, 2020 Criteria or Requirement Under the Federal Register (82 FR 29061), all schools receiving Pell grants submit Pell payment data to the Department through the Common Origination and Disbursement (COD) System. Institutions must report student payment data within 15 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, biweekly or weekly or may set up their own system to ensure that changes are reported in a timely manner. Condition and Context During our testwork, we selected a sample of 40 students that were awarded Pell funding during fiscal year 2020. Within our sample, we noted 7 instances across 5 students in which the College did not submit the payment data to the COD within 15 days as required. Cause and Potential Effect Noncompliance due to a lack of established internal controls to ensure that all reports of Pell funding are submitted on a timely basis. The Pell reporting exceptions are systemic in nature. Questioned Cost There were no questioned cost associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation We recommend that the College strengthen its processes and controls to ensure timely reporting of Pell grant funding to students and that additional supervisory review procedures be implemented to monitor timely reporting of Pell disbursements. View of Responsible Officials Management agrees with the finding. A new process will be implemented within Financial Aid Department to meet the 15 day reporting requirement.

Finding No. 2020 002 Reporting Federal Program Education Stabilization Fund CFDA No. 84.425E ? COVID 19 ? Higher Education Emergency Relief Fund Student Aid Portion (HEERF) Federal Agency U.S. Department of Education Federal Award Years October 1, 2019 to September 30, 2020 Criteria or Requirement Beginning on May 6, 2020, the U.S. Department of Education required institutions that received a HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). Per the Federal Register notice posted on August 31, 2020, subsequent reports are due quarterly and must be posted no later than 10 days after the calendar quarter. These reports are required to be timely and accurate, with the following elements identified as critical information in the 2020 Office of Management and Budget Compliance Supplement Addendum: ? Item #3: The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). ? Item #4: The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act. ? Item #5: The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act. ? Item #6: The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act. Condition and Context During our testwork, we examined the HEERF student aid portion public report posted to the institution?s website dated May 22, 2020. We noted that the following key line items identified as critical information were not reported accurately in the student aid portion public report posted to the institution?s website: the total reported amount of federal aid distributed to students ($806,500) and the total reported number of students who had received an emergency financial aid grant under section 18004(a)(1) of the CARES Act (1,095 students) in the May 22, 2020 report did not agree to supporting documentation or the general ledger, with an unreconciled difference of approximately $68,000 in the amount of federal aid distributed (overstated in the public student aid portion report) and an unreconciled difference of approximately 98 students who had received emergency financial aid grants (also overstated in the public student aid portion report). Cause and Potential Effect Noncompliance due to a lack of established internal controls to ensure that all information required to be included in HEERF interim and other required reports is accurately reported and reconciles to supporting documentation and the general ledger. Questioned Cost There were no questioned cost associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation We recommend that the College strengthen its processes and controls to ensure timely and accurate reporting of HEERF expenditures and that additional supervisory review procedures be implemented to identify and resolve unreconciled differences prior to finalization and submission of required reports. View of Responsible Officials Management agrees with the finding. Steps have been taken within Business and Finance to reconcile the support to the report before it is posted to the College?s website.

Finding No. 2019-003 Eligibility and Special Tests and Provisions Federal Programs: Student Financial Assistance Cluster CFDA Nos.: 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grant 84.268 ? Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Federal Award Years: October 1, 2017 to September 30, 2018 October 1, 2018 to September 30, 2019 Criteria or Requirement Section 200.303 of the Uniform Guidance requires nonfederal entities to establish and maintain internal control over federal awards to be in compliance with guidance in ``Standards for Internal Control in the Federal Government,?? issued by the Comptroller General of the United States, and the ``Internal Control Integrated Framework,?? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The COSO framework requires management to maintain documentation to provide clarity around roles and responsibilities, which promotes consistency in adhering to the entity?s practices, policies, and procedures; to assist in capturing the design of internal control and setting expectations of performance and conduct; to assist in training new personnel and to offer a reference for other employees; to provide a means to retain organization knowledge; and to provide evidence of the conduct of internal control, enable proper monitoring, and support reporting. Condition and Context During our testwork over the design and implementation of certain controls in the Student Financial Aid Cluster, we noted that the College relies on general information technology application controls over eligibility and special tests and provisions. As a result of finding 2019-002, the engagement team determined to test the manual controls over these compliance provisions. The College was unable to provide the sufficient supporting documentation over the design and implementation of the related manual controls in the following areas: eligibility, loan disbursements, enrollment reporting, and borrower data and transmission. As a result of insufficient documentation retained by the College, we were unable to conclude over the operating effectiveness of these controls.Cause and Potential Effect Management did not retain supporting documentation to demonstrate that manual controls around eligibility and certain special tests and provisions compliance requirements are properly designed and implemented, and as a result, the operating effectiveness of manual controls could not be tested for fiscal year 2019. Questioned Cost There were no questioned cost associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat finding in the immediately prior audit This is not a repeat finding. Recommendation We recommend that the College enhance its documentation over its processes and controls and maintain related supporting documents around compliance requirements of the Student Financial Aid Cluster. View of Responsible Officials Enrollment Management will re-emphasize among staff, Policy IT 100.5 Password Management Guidelines.

Finding No. 2019-004 Enrollment Reporting Federal Programs: Student Financial Assistance Cluster CFDA Nos.: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Federal Award Years: October 1, 2017 to September 30, 2018 October 1, 2018 to September 30, 2019 Criteria or Requirement Under the Pell grant and loan programs, institutions must complete and return to the Department of Education within 30 days the Enrollment Reporting roster file (Pell, 34 CFR Section 690.83(b)(2); FFEL, 34 CFR Section 682.610; and Direct Loan, 34 CFR Section 685.309). Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the National Student Loan Data System (NSLDS) website. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition and Context During our testwork over the Student Financial Aid Cluster, we selected a sample of 40 students who were awarded federal aid assistance with status changes during fiscal year 2019. Within our sample, we noted one instance in which the student?s status change was not submitted to the NSLDS within 60 days as required. Cause and Potential Effect Noncompliance due to a lack of established internal controls to ensure that all reports of student status changes are submitted on a timely basis. As a result, one student status change was not submitted in the 60-day requirement period. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit A similar finding was reported in the prior year?s audit as finding number 2018-001. Recommendation We recommend that the College strengthen its processes and controls within the Registrar?s Office to ensure that student status changes are communicated timely to the NSLDS and that additional supervisory review procedures be implemented to monitor timely reporting of status changes and required transmissions. View of Responsible Officials Management concurs with the one enrollment finding. The corrective action items of the previous fiscal year have been implemented. However, the staffing level during the year impacted the ability to timely identify the request to update the enrollment status.

Finding No. 2019-005 Special Tests and Provisions ? Disbursement Notification Federal Programs: Student Financial Assistance Cluster CFDA No.: 84.268 ? Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Federal Award Years: October 1, 2017 to September 30, 2018 October 1, 2018 to September 30, 2019 Criteria or Requirement The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than 7 days after, crediting the student?s account and must give the student 30 days (instead of 14) to cancel all or part of the loan. Condition and Context From a sample of 40 students who received federal aid, we noted 25 students whose notification did not include all disbursements (specifically PLUS loans), 7 students who were correctly notified but outside the allowable notification period, 5 students who were not notified of one or more disbursements, and 1 student whose notification amounts did not agree to the actual amount disbursed to that student. Cause and Potential Effect Noncompliance due to a lack of established internal controls to ensure that all aid disbursement notifications are generated completely, accurately, and delivered timely to students. The disbursement notification exceptions are systemic in nature.Questioned Cost None. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit This is not a repeat finding. Recommendation We recommend that the College strengthen its processes and controls around aid disbursement notifications to ensure the notifications generated are complete, accurate, and delivered timely to students. View of Responsible Officials Management concurs with the finding. Overloaded staff members caused the increase in error rates. Procedures have been put in place to correct the issues.

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