THE UNIVERSITY OF TAMPA, INC.Higher Education

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.063 - Federal Pell Grant Program Award Period: June 1, 2020 to May 31, 2021 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2)) funds to a student. Condition: During our testing of reporting Pell disbursements to common origination and disbursement (COD) we noted discrepancies in the timeliness of disbursements reported to COD in 3 of the 40 disbursements tested. Questioned Costs Known: None Context: 3 out of 40 Pell grant disbursements tested were not reported timely. Cause: The 3 disbursements were rejected by COD when originally submitted however the University did not follow up on them timely to resubmit. Ultimately, they were resolved by the University. Effect: Non-Compliance with federal regulations which could lead to late repayment terms for students. Repeat Finding: No. Recommendation: We recommend that the University review their policies and procedures to ensure timely reporting to COD. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.268 Federal Direct Student Loan Program Award Period: June 1, 2020 to May 31, 2021 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify 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. 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. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 37 of 40 students tested had one or more instances of noncompliance noted below: I. Two instances where the student?s Campus and Program enrollment statuses were not updated in NSLDS from an in school status to a terminal status. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) II. One instance where the student?s Campus and Program enrollment status was not updated in NSLDS related to a change in their enrollment status. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) II. One instance where the student?s campus and program enrollment effective date was incorrectly reported to NSLDS for a terminal status. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) III. One instance where the student?s program enrollment effective date was incorrectly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) IV. 36 instances where the students program begin date reported to NSLDS did not agree to the University?s records. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) Questioned Costs Known: None. Context: Out of a sample of 40 students selected for testing for the requirement noted above, we noted the exceptions as described above. While the requirements for the campus level enrollment effective dates, program length, and program enrollment effective dates are not new, this is the first year this is required to be tested per the OMB Compliance Supplement. Cause: All instances of noncompliance above were due to the institution implementing their new student information system. Effect: The NSLDS system is potentially not updated with correct student information which could cause subsequent repayment and awarding discrepancies. Repeat Finding: Yes. Recommendation: We recommend that the College review their policies and procedures regarding enrollment reporting within the new student information system to ensure that reporting is completed accurately and timely. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.063 - Federal Pell Grant Program Award Period: June 1, 2019 to May, 31, 2020 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student?s EFC and the enrollment status of the student. Condition: During our eligibility testing, 2 of the 23 students tested were disbursed an incorrect amount of Pell grant funds. One of the students was under awarded and one student was over awarded Pell grant funds. Questioned costs Known: $294 Context: 2 out of 23 students tested were not awarded correctly. Cause: The Pell grant for the under award was computed with an incorrect EFC, while the Pell grant for the over award used the incorrect number of weeks in the Winter Intersession to compute the award. Effect: The students were awarded the incorrect amount of Pell funds. Repeat Finding: No. Recommendation: We recommend that the University implements a review process to determine that nonstandard terms are calculated correctly, and that the correct EFC is used. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.268 Federal Direct Student Loan Program Award Period: June 1, 2019 to May 31, 2020 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition: During our testing, we noted 2 instances out of 26 students tested where the subsidized Stafford loan awarded to the student was less than the maximum amount, they were eligible for. Questioned costs Known: $2,442. Context: 2 out of 26 students tested were not awarded correctly. Cause: The University did not appropriately determine the student?s level of education when awarding the Subsidized Stafford Loan, and incorrectly decreased the student?s subsidized loan to prevent over award. Effect: The student could have received additional need based aid in the form of subsidized loans instead of unsubsidized loans. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.268 Federal Direct Student Loan Program Award Period: June 1, 2019, to May 31, 2020 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing of 40 students, we noted four instances of late reporting of student status changes. Questioned costs Known: None. Context: 4 out of 40 students tested were not reported timely. Cause: The University?s processes and controls did not ensure that student status changes were reported to NSLDS within the required time frame. Effect: The NSLDS system is not updated with the student information timely which could lead to student?s grace period being shortened. Repeat Finding: No. Recommendation: We recommend the University review its reporting procedures to ensure that students? statuses are reported to NSLDS within the required time frame. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.

Finding 2019-002: Reporting Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Federal Award Year: July 1, 2018 to June 30, 2019 Criteria or Specific Requirement ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campus-based programs. The school uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. 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 Found During our testwork over the FISAP submitted on September 28, 2018, we identified two instances of incorrect numbers submitted in Part V, including an incorrect number of students on line 24 and an incorrect breakout of community service funds between lines 25 and 26. Cause and Possible Asserted Effect The University?s FISAP reporting process does not include an independent review by someone other than the preparer, as University personnel obtain the support, enter the information into the FISAP, and review their own data entry. Questioned Costs None. Whether the Sample Was a Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding Was a Repeat Finding in the Immediately Prior Audit No similar findings were noted in the prior year audit report. Recommendation We recommend the University design and implement internal controls that involve segregation of duties between the individuals entering data into the FISAP and the individuals reviewing the data entered prior to submission of the FISAP.View of Responsible Officials Managerial review of the FISAP was conducted to ensure that the data entry on the final FISAP reported to the USDOE was accurate. Managerial review failed to catch errors in the underlying data to support the information reported on the final FISAP report. Effective with the next reporting of the FISAP, due September 2019, management review will include the underlying data to support the information reported on the FISAP.

Finding 2019-003: Return of Title IV Funds Federal Agency: U.S. Department of Education Federal Program: CFDA 84.063 Federal Pell Grant Program CFDA 84.268 Federal Direct Student Loans Federal Award Year: July 1, 2018 to June 30, 2019 Criteria or Specific Requirement Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education (ED) 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 Section 668.173(b)). 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 Found Of the 40 students selected for the Return of Title IV Funds testing, we identified two students whose funds (Direct Loans and Pell) were not returned to ED within the allotted 45 day time frame from the date the University determined the students withdrew. The total amount of funds returned late to ED from these two students consisted of $4,943 of Direct Loans and $2,507 of Pell. Cause and Possible Asserted Effect The University returns funds to ED through their cash drawdowns in the G5 system by including the refunds as credits to the draw down. The University typically performs these draw downs at least monthly. However, a draw down was not performed in March 2019 which resulted in a late return of funds for students who withdrew between February 23, 2019 and March 15, 2019. Management performed an analysis of students who withdrew during this time frame and determined that $15,551 of Direct Loans and $2,853 of Pell was returned late to ED for an additional 5 students. Questioned Costs None. The unearned funds were appropriately removed from the student?s accounts, however they were not timely remitted to ED.Whether the Sample Was a Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding Was a Repeat Finding in the Immediately Prior Audit No similar findings were noted in the prior year audit report. Recommendation We recommend the University design and implement internal controls that will ensure return of Title IV funds are performed timely as required by ED. View of Responsible Officials The University of Tampa will enhance the existing control activities surrounding the timely return of Title IV funds to ensure compliance with the 45 day return policy.

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