University of MiamiHigher Education

Finding 2024-001: Enrollment Reporting Federal Agency U.S. Department of Education Federal Program Student Financial Assistance Cluster (ALN #84.268) Federal Award Year July 1, 2023 through June 30, 2024 Federal Award Numbers P268K221285 Criteria 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 During our procedures performed over the Student Financial Assistance Cluster, we selected a sample of 40 students who were awarded federal student financial aid with status changes during fiscal year 2024. Within our sample, we noted five instances in which the student’s status change was not submitted to the NSLDS within 60 days as required. Cause and Effect The control to ensure that all reports of student status changes are submitted to NSLDS on a timely basis was not operating effectively to identify certain instances of noncompliance. For each student identified where there was a delay, the withdrawal status was not transmitted timely to NSLDS by a range of 4 – 33 days. This was due to technical difficulties the University had with the National Student Clearinghouse (NSC) which prevented timely transmission to NSLDS. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance the precision of the control around the review of timeliness of the enrollment reporting submissions. Views of Responsible Officials UM management acknowledges that the status changes for 5 out of 40 students selected were not reported to NSLDS within the required 60-day timeframe. This delay was caused by unexpected technical issues during the submission process to the National Student Clearinghouse. UM management has since implemented a new process for reporting submission to bypass the technical issues.

Finding 2022-001: Enrollment Reporting Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285; P063P211285 Criteria Per Section 34 CFR 685.309, a school shall update the student status confirmation report for changes in student status, report the date the enrollment status was effective and return the student status confirmation report to the Secretary within 60 days of receipt. Per Section 4.4.3 of the National Students Loan Data System (NSLDS) enrollment reporting guide, reporting of graduated status is critical to the protection of a student?s interest subsidy and initiation of repayment periods. Per the NSLDS Enrollment Guide section 4.4.2, the NSLDS has defined the effective date, for both program level and campus level reporting, to be significant data elements. The NSLDS Enrollment Guide states that the effective date for a withdrawal status should be the final day of the term in which the student was last enrolled. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 1 out of 40 students, the student had graduated but the status change was not reported at the campus level or at the program level. For 1 out of 40 students, the student had graduated but the status change was not reported at the program level. For 14 out of 40 students, the effective date of the students? withdrawal status per the program level reporting did not agree to student withdrawal status? effective date per campus level reporting. The campus level effective date was the last day of the Fall semester and the program level effective date was the first day of Spring semester. Cause and Effect The control that management sets a predetermined schedule to submit an enrollment report, on at least a monthly basis is to ensure timely reporting to the NSLDS, and reviews all reports for the accuracy of all data elements prior to submission was not operating at a level to identify all discrepancies. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance the precision of the control around the review of accuracy and timeliness of the program level and campus level enrollment reporting submissions. Views of Responsible Officials: See management?s corrective action plan.

Finding 2022-002: Pell Grant and Direct Loan Reporting Federal Agency U.S. Department of Education Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285; P268K226696; P063P211285 Criteria Per OMB No. 1845-0039, the University is required to submit Pell and Direct Loan disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. Per 34 CFR 668.164, the disbursement date is the date that the institution credits the student?s ledger account or pays the student or parent directly. As a key item to the disbursement records, the disbursement date per COD should agree to the disbursement date per the student?s ledger account. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 40 out of 40 students, the Direct Loan disbursement date per the student?s account does not agree to the disbursement date per the COD by one day. For 5 out of 40 students, the Pell Grant disbursement date per the student?s account does not agree to the disbursement date per COD by one day. Cause and Effect The University?s control for reviewing the timeliness of the information submitted for the disbursement records did not operate effectively to identify all errors. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance its control around the Direct Loan and Pell Reporting for disbursement records to ensure all reported information agrees between the student?s account ledger and the COD records. Views of Responsible Officials: See management?s corrective action plan.

Finding 2022-003: Loan Disbursement Notifications Federal Agency U.S. Department of Education Federal Program Student Financial Assistance Cluster (CFDA # 84.268) Federal Award Year July 1, 2021 through June 30, 2022 Federal Award Numbers P268K221285 Criteria Per 34 CFR section 668.165, if an institution credits a student?s account with a Direct Loan, the institution must notify the student or parent, no earlier than 30 days before the disbursement and no later than 30 days after the disbursement, in writing of the anticipated date and amount of the loan disbursement, 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, and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 28 out of 40 students, the federal direct loan disbursement notification was not sent to the student or parent within the required 30 days before or 30 days after the disbursement was credited to the student?s account. Cause and Effect The University?s internal controls for determining that a loan disbursement notification was sent timely for each disbursement made were not operating effectively. Accordingly, the University did not send a loan notification for disbursements within the required timeframe. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University enhance the precision of the controls over loan disbursements to ensure that all loan disbursements through the Federal Direct Student Loan Program have a written notification sent to the student and/or parents within the required timeline of within 30 days before and 30 days after the disbursement date. Views of Responsible Officials: See management?s corrective action plan.

Finding 2022-004: Reporting Federal Agency U.S. Department of Education Federal Program COVID-19 ? Education Stabilization Fund (CFDA 84.425E and F) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Federal Award Numbers P425E200069; P425F200985 Criteria There are three components to reporting for 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) programs, as applicable; and the (3) the annual report. For Coronavirus Aid, Relief, and Economic Security Act (CARES), beginning on May 6, 2020, ED required institutions that received a HEERF I Section 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). This was announced through an electronic announcement (EA). On August 31, 2020, the U.S. Department of Education (ED) revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan Act (ARP), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days Finding 2022-004: Reporting Federal Agency U.S. Department of Education Federal Program COVID-19 ? Education Stabilization Fund (CFDA 84.425E and F) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Federal Award Numbers P425E200069; P425F200985 Criteria There are three components to reporting for 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) programs, as applicable; and the (3) the annual report. For Coronavirus Aid, Relief, and Economic Security Act (CARES), beginning on May 6, 2020, ED required institutions that received a HEERF I Section 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). This was announced through an electronic announcement (EA). On August 31, 2020, the U.S. Department of Education (ED) revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan Act (ARP), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Institutions are required to be both timely and accurate in publicly posting its Student Aid Portion Reports from May 6, 2020, onward. A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. Institutions of Higher Education must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which is due July 10, 2021. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition While without funding for the period, for the calendar quarters ended September 30, 2021 and March 31, 2022, a quarterly report for the Student Aid Portion was not posted. For the calendar quarter ended June 30, 2021, the quarterly report for the Student Aid Portion and Institutional Portion was not submitted within the required 10 days of the quarter end. For the calendar quarter ended September 30, 2021, the quarterly report for the Institutional Portion was not submitted within the required 10 days of the quarter end. Rather the reports were submitted within 15 and 12 days, respectively, of the quarter end. For the calendar quarters ended June 30, 2021 and December 31, 2021, the information reported on the Student Aid Portion quarterly reports for three of the four key line items, was not accurate. The three key line items included total amount distributed to students, number of students that were eligible, and number of students that received a distribution. For the quarter ended June 30, 2021, the total amount distributed to students was inaccurate by $118,403 and the number of students that were eligible and number of students that received a distribution were inaccurate by 13 students. For the quarter ended December 31, 2021, the total amount distributed to students was inaccurate by $21,134 and the number of students that were eligible and number of students that received a distribution were inaccurate by 167 students. Cause and Effect Management?s review control over its reporting requirements for HEERF was not operating at a level of precision to ensure timely and accurate reporting. Therefore, certain required reporting was not posted publicly or submitted, was not submitted timely, or was not accurate. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation Given the nature of the pandemic funding, and the evolving guidance of the compliance requirements, we recommend management enhance its process level controls over reporting requirements for HEERF. Views of Responsible Officials: See management?s corrective action plan.

Finding 2022-005: Reporting Federal Agency U.S. Department of Health and Human Services Federal Programs COVID-19 ? Provider Relief Fund (CFDA 93.498) Federal Award Year July 1, 2020 through June 30, 2021 and July 1, 2021 through June 30, 2022 Criteria The Provider Relief Fund (PRF) reporting portal should be accurate, including the line item Total Other Provider Relief Fund Expenses. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition The University submitted their PRF period one portal reporting on September 30, 2021 which reflected $114,692,613 of Lost Revenues and $14,854,235 of Other Provider Relief Fund Expenses. An amended PRF period one portal reporting was submitted on June 27, 2022 which reflected lost revenues of $114,692,613 and $0 of Other Provider Relief Fund Expenses. The amended period one portal reporting was filed after the due date. Cause and Effect Management?s review control over its reporting requirements for PRF was not operating at a level of precision to initially ensure its accuracy. When management identified an amended report was required, the update to the portal reporting was not made timely. Management did identify and correct the reporting. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation Given the nature of the pandemic funding, and the evolving guidance of the compliance requirements, we recommend management enhance its process level controls over the reporting requirements with an emphasis on making timely updates, as necessary. Views of Responsible Officials: See management?s corrective action plan.

Finding 2021-001: Procurement Federal Agency U.S. Department of Health and Human Services; U.S. Department of Defense Federal Program Research and Development Cluster Federal Award Number and Federal Award Year CFDA:12.300 Federal Award Number N00014-19-1-2514 Federal Award Year April 15, 2019 through November 30, 2021 CFDA:12.UNK Federal Award Number 20S11S Federal Award Year September 10, 2020 through August 20, 2021 CFDA:93.866 Federal Award Number U01AG057659 Federal Award Year September 30, 2017 through August 31, 2021 CFDA:93.866 Federal Award Number U01AG066767 Federal Award Year July 1, 2020 through June 30, 2021 Criteria Per 2 CFR Section 215.46, procurement records shall include at a minimum: 1) basis for contractor selection; 2) justification for lack of competition, and 3) basis for price. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 8 of 40 procurement transactions sampled, there was not sufficient documentation maintained to justify the lack of competition related to each procurement at the time of purchase. The documentation that was subsequently provided did justify the lack of competition. Cause and Effect The control to ensure that procurement transactions have documentation to support the lack of competition at the time of purchase was not operating effectively. As a result, there were procurement transactions that did not include documentation sufficient to support lack of competition prior to the purchase authorization. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the University reinforce their procurement policies and procedures, which are designed to comply with 2 CFR Section 215.46, to ensure that approval of a sole-source procurement transaction includes the review over the documentation of justification for lack of competition. This documentation should be maintained. Views of Responsible Officials: See management?s corrective action plan.

2019-001 ? Verification Special Tests and Provisions U.S. Department of Education Title: Student Financial Assistance Cluster; CFDA#: Various Federal Award Year: 2018-2019 Criteria or specific requirement: 2 CFR Part 200, Appendix XI, Compliance Supplement 2018 for Student Financial Assistance Programs {III. Compliance Requirements, N. Special Tests and Provisions, 2. Verification ? Updating Information. (34 CFR 668.55 (b)(1)} stipulates an applicant who is selected for verification of the number of persons in his or her household (household size) or the number of those in the household who are attending post-secondary institutions (number in college) must update those items to be correct as of the date of verification, except when the update is due to a change in his or her marital status. Condition: The audit test work noted that the applicant information was not consistently updated in accordance with the regulations. Cause: The staff made errors in documenting the items required for verification, and independent review did not identify and correct the errors. Effect: Incorrect information reported on the Institutional Student Information Records (ISIRs) could lead to improper amounts being distributed for awards, which may require the University to remit funds back to the granting agency or could result in a student being under-awarded. Questioned costs: Not determinable. Context: The student profiles for three of the 60 students selected contained information that did not agree to the supporting documentation obtained by the University during the financial aid application process. The correct information was received and retained by the University, but was not corrected in the ISIRs. Identification as a repeat finding: 2018-001 Recommendation: We recommend that management train the staff responsible for the verification to follow the documentation requirements and that management review the student files to determine compliance. Views of responsible officials: See management?s corrective action plan.

2019-002 ? Eligibility Special Tests and Provisions U.S. Department of Education Title: Student Financial Assistance Cluster; CFDA#: Various Federal Award Year: 2018-2019 Criteria or specific requirement: 2 CFR Part 200, Appendix XI, Compliance Supplement for Student Financial Assistance Programs {III. Compliance Requirements, E. Eligibility ? Eligibility for Individuals}. The determination of student financial aid award amounts is based on financial need. Financial need is generally defined as the student?s cost of attendance (COA) minus financial resources reasonably available. Federal regulations for cost of attendance components (Vol 3, Chapter 2, p.34) states that such adjustments must be documented in the student's file. Condition: Our audit testing reported an instance where the cost of attendance was not properly supported. Cause: The staff responsible for the calculation of the COA did not properly follow federal compliance requirements. Effect: Improper calculation of the COA could lead to improper amounts being distributed for awards, which may require the University to remit funds back to the granting agency or could result in a student being under-awarded. Questioned costs: Not determinable. Context: One of the 60 students tested did not have the required supporting documentation to support adjustments used in the COA calculation within their student file. Identification as a repeat finding: 2018-003 Recommendation: We recommend management develop processes and policies to ensure that all COA calculations are properly supported. Views of responsible officials: See management?s corrective action plan.

2019-003 ? Borrower Data Transmission and Reconciliation Special Tests and Provisions U.S. Department of Education Title: Student Financial Assistance Cluster; CFDA#: Various Federal Award Year: 2018-2019 Criteria or specific requirement: 2 CFR Part 200, Appendix XI, Compliance Supplement for Student Financial Assistance Programs {III. Compliance Requirements, N. Special Tests and Provisions, 8. Borrower Data Transmission and Reconciliation} stipulates institutions must report all loan disbursements and submit the required documents to the Direct Loan Servicing System (DLSS) via the Common Origination and Disbursements (COD) within 15 days of disbursement. Condition: Our audit testing reported instances where the date reported to the COD did not agree to the date the funds were credited to the student account system. Cause: The staff responsible for reporting loan disbursements did not properly follow federal compliance requirements. Effect: Reporting inaccurate information of loan disbursements results in noncompliance with the COD reporting requirements. Questioned costs: None. Context: Three of the 60 students tested reported the incorrect disbursement date during the spring semester. Identification as a repeat finding: 2018-003 Recommendation: We recommend management develop processes, policies and controls to properly identify and report all loan disbursements accurately and in a timely fashion. Views of responsible officials: See management?s corrective action plan.

2019-004 ? Disbursements Special Tests and Provisions U.S. Department of Education Title: Student Financial Assistance Cluster; CFDA#: Various Federal Award Year: 2018-2019 Criteria or specific requirement: 2 CFR Part 200, Appendix XI, Compliance Supplement for Student Financial Assistance Programs {III. Compliance Requirements, N. Special Tests and Provisions, 3. Disbursements To or On Behalf of Students ? Notices. (34 CFR 668.165 (a))} stipulates, before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. If an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of the anticipated date and amount of the disbursement; the student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. The institution must provide the notice no earlier than 30 days before, and no later than 30 days after, crediting the student's ledger account at the institution, if the institution obtains affirmative confirmation from the student; or no earlier than 30 days before, and no later than seven days after, crediting the student's ledger account at the institution, if the institution does not obtain affirmative confirmation from the student. Condition: Our audit test work found that the required Student Financial Aid (SFA) notices of disbursement of loan funds and the right to cancel notifications were not sent within the required timeframes. Cause: Reliance was placed on the information system software to automatically generate the notifications. The control was not activated resulting in late notifications. Effect: The University could be at risk for future reductions of funding under the SFA Cluster. Questioned Costs: None. Context: 39 out of the 60 students tested in the fall and one of 60 students tested in the summer for loan notification were not notified within seven days after the student?s ledger account was credited as required due to a systematic error. Identification as a repeat finding: No Recommendation: We recommend that management review and test notifications generated by the system to ensure proper and timely notifications are made. We also recommend that internal controls be implemented to ensure the process is operating as designed and that the notifications are prepared and sent on a timely basis. Views of responsible officials: See management?s corrective action plan.

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