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Federal Agency: U.S. Department of Education Assistance Listing Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Cash Management Questioned Cost: $55,915 Criteria: 34 CFR 668.162(d) states that under the heightened cash monitoring payment method, an institution must credit a student's ledger account for the amount of Title IV HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due under ? 668.164(h), before the institution submits a request for funds under the provisions of the advance payment method described in paragraphs (b)(1) and (2) of 34 CFR 668.162, except that the institution's request may not exceed the amount of the disbursements the institution has made to the students included in that request. Condition: Of the 75 samples tested, we noted 29 samples (or 39%) where the University did not credit the student?s ledger account before submitting a request for funds. Further, we noted 3 (or 4%) samples where the University made the disbursement beyond 3 days following the receipt of funds. Cause: The University lacks effective controls to ensure compliance with cash management requirements. Effect: The University is noncompliant with cash management requirements. Known questioned costs exist amounting to $55,915. Identification as a repeat finding: 2021-005 Recommendation: The University?s management should review the requirements of the Uniform Guidance and coordinate with its third-party private financial aid consultant in developing and implementing effective controls over compliance with cash management requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Reporting Questioned Cost: $0 Criteria: Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system (OMB No. 1845-0039). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified the disbursement date as one of the key items. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is an electronic report submitted annually to receive funds for the campus-based programs (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Part 5 L. Reporting of the 2022 OMB Compliance Supplement identified various line items as key items containing critical information. Condition: 1. Out of 31 samples of disbursements tested, we noted 22 (or 71%) disbursements where the disbursement date per student account ledger did not match the disbursement date reported in the COD system. 2. We noted differences in the key line items reported in the FISAP report and per the underlying records as follows: "See Schedule of Findings and Questioned Costs for the table" Cause: The University lacks adequate review controls to ensure the accuracy of information being reported in the COD system and in the FISAP report. Effect: The University is noncompliant with reporting requirements. Recommendation: The University should implement review controls over reports required to be submitted for the programs under the SFA cluster. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster ? 84.268 Federal Direct Student Loans Award Number: Various Area: Special Tests and Provisions ? Disbursements to or on Behalf of Students Questioned Cost: $0 Criteria: An additional requirement of the Direct Loan program is that institutions must implement a quality assurance system (34 CFR 685.300(b)(9)). Conditions No documentation was provided of the University?s Direct Loan quality assurance system. Cause: The University is not familiar with the requirements of special tests and provisions. Effect: The University is noncompliant with the requirements of the special test and provisions on disbursements to or on behalf of students. Recommendation: The University must implement procedures to improve its knowledge of special tests and provisions required for the federal programs under the SFA cluster. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster ? 84.268 Federal Direct Student Loans Award Number: Various Area: Special Tests and Provisions ? Direct Loan Reconciliation Questioned Cost: $0 Criteria: 34 CFR 685.300(b)(5) requires institutions to reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary (through School Account Statements (SAS) from COD)). Condition: No documentation was provided for monthly reconciliations performed from July to December 2021. Cause: The University only started performing reconciliations in January 2022 with the assistance of its third-party financial aid private consultant. Effect: The University is noncompliant with the requirements of the special test and provisions on direct loan reconciliation. Identification as a repeat finding: 2021-009 Recommendation: The University must implement monitoring controls over the monthly direct loan reconciliation process performed by the third-party financial aid private consultant. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Federal Agency: U.S. Department of Education ALN and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Tests and Provisions ? Return of Title IV Funds Questioned Cost: $0 Criteria: 34 CFR 668.20(d) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. 34 CFR 668.22(j) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition: Of the five (5) samples tested, we noted one (1) sample where the University did not return the funds within the required time frame. Cause: The University?s management is not experienced with handling title IV funds and was not aware that there is a timeline to return funds for non-attendance or withdrawal of students. Effect: The University is noncompliant with the requirements of the special test and provisions on return of Title IV funds. Identification as a repeat finding: 2021-008 Recommendation: The University should improve its controls over the timely determination of whether a student has ceased attendance for purposes of computing a return of Title IV funds. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Finding No. 2021-002 Federal Agency: U.S. Department of Education CFDA Number and Title: 84.425N COVID-19 Funds for the Improvement of Postsecondary Education (FIPSE) Formula Grant Award Number: P425N200845 Area: Activities Allowed or Unallowed and Allowable Costs/Cost Principle Questioned Costs: $128,950 Criteria: Public Law 116-136 Coronavirus Aid, Relief and Economic Security (CARES) Act section 18004(b) requires grantees to use the federal awards to defray expenses to include loss of revenue, reimbursement for expenses already incurred, technology costs associated with a transition to distance education, faculty and staff training payroll and for grants to students for any component of the student?s cost of attendance. Condition: We tested 35 transactions totaling $212,191 out of a total population of $347,923. We noted seven (7) transactions totaling $128,950 were used for major renovations of the University. These are not allowable activities and costs. Cause: The University?s management is not experienced with administering the new federal programs associated with COVID-19. Effect: The University is noncompliant with the requirements of activities allowed or unallowed and allowable cost/cost principle. Recommendation: The University?s management should review the Uniform Guidance requirements and the public law that enabled the CARES Act and improve its procedures on reviewing the allowability of activities and costs charged to the grant. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Finding No. 2021-003 Federal Agency: U.S. Department of Education CFDA Number and Title: 84.425N COVID-19 Funds for the Improvement of Postsecondary Education (FIPSE) Formula Grant Award Number: P425N200845 Area: Procurement, Suspension and Debarment Questioned Cost: $0 Criteria: 2 CFR 200.317 states that an entity must follow the same policies and procedures it uses for procurement from its non-Federal funds. The University?s procurement procedures states that a requisition form must be approved by the Vice President (below $1,000), President ($1,000 - $10,000), or the Board (above $10,000). In addition, the purchase order must be reviewed by the Vice President. Condition: We tested 35 transactions of which 34 did not have the required supporting documents as stated in the University?s procurement procedures. Cause: The University?s procurement procedure is not operating as designed. Effect: The University is noncompliant with the requirements of the procurement principle. Recommendation: The University?s management should enforce their procurement procedures. In addition, the University?s management should revise their procurement procedures to include a section for micro-purchases in line with the requirements of the Uniform Guidance. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Finding No. 2021-004 Federal Agency: U.S. Department of Education CFDA Number and Title: 84.425N COVID-19 Funds for the Improvement of Postsecondary Education (FIPSE) Formula Grant Award Number: P425N200845 Area: Matching, Level of Effort and Earmarking Questioned Costs: $172,491 Criteria: Public Law 116-136 section 18004(c) states the higher education shall use no less than 50 percent of funds to provide emergency financial aid grants to students for expenses related to the disruption of campus operation due to coronavirus. Condition: The University did not use 50 percent of the funds to provide emergency financial aid to students. Of the $347,923 awarded to the University under the 84.425N FIPSE grant, only 0.42% or $1,470 was used for emergency financial aid grants to student. Cause: The University?s management is not experienced with administering the new federal programs associated with COVID-19. Effect: The University is noncompliant with the requirements of the earmarking principle. Recommendation: The University?s management should review the Uniform Guidance and the public law that enabled the CARES Act to understand the compliance requirements on the use of such federal funds. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Finding No. 2021-005 Federal Agency: U.S. Department of Education CFDA Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Cash Management Questioned Cost: $0 Criteria: 34 CFR 668.162(d) states that the institution must credit a student?s ledger account for the amount of the Title IV, Higher Education Act program funds that the student or parent is eligible to receive before the institution seeks reimbursement for those disbursements under the provisions. Condition: Of the 25 samples tested, we noted that seven (7) samples where the University did not credit the student?s account before requesting reimbursement. Cause: The University was placed in heightened cash monitoring payment method. The University?s management is not experienced with administering the cash management requirements. Effect: The University is noncompliant with the requirements of the cash management principle. Recommendation: The University?s management should review the requirements of the Uniform Guidance and comply with the cash management principal requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Finding No. 2021-006 Federal Agency: U.S. Department of Education CFDA Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Reporting Questioned Cost: $0 Criteria: 34 CFR 668.162(c) states that an institution seeks reimbursement by submitting to the Secretary a request for funds that does not exceed the amount of the disbursements that institution has made to students or parents included in that request. Condition: The University could not provide supporting documents that they submitted form SF-270, request for advance or reimbursement form. Cause: The University?s management was not aware of the requirements of form SF-270. Effect: The University is noncompliant with the requirements of the reporting principle. Recommendation: The University?s management should review the requirements of the Uniform Guidance and comply with the reporting principal requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Finding No. 2021-007 Federal Agency: U.S. Department of Education CFDA Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Test and Provisions Questioned Cost: $0 Criteria: 34 CFR 674.19(e) states that an institution shall retain a record of disbursements for each loan made to a borrower on a Master Promissory Note. This record must show the date and amount of each disbursement. In addition, an Institution shall maintain a repayment history for each borrower. This repayment history must show the date and amount of each repayment over the life of the loan. It must also indicate the amount of each repayment credited to the principal, interest, collection costs and either penalty or late charges. Condition: The University was not able to provide a record of disbursement and repayment history that properly reconciles Federal Student Loans. Cause: The University?s management is not aware of Federal Student Loan requirements. Effect: The University is noncompliant with the requirements of the special test and provisions principal. Recommendation: The University?s management should review the requirements of the Uniform Guidance and comply with the special test and provisions principal requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Finding No. 2021-008 Federal Agency: U.S. Department of Education CFDA Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Test and Provisions Questioned Cost: $0 Criteria: 34 CFR 668.20(d) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. 34 CFR 668.22(j) states that an institution must return the amount of title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition: Of the five (5) samples tested, we noted that four (4) samples where the University did not return the funds within the required time frame. Cause: The University?s management is not experienced with handling title IV funds and was not aware that there is a timeline to return funds for non-attendance or withdrawal of students. Effect: The University is noncompliant with the requirements of the special test and provisions principal. Recommendation: The University?s management should review the requirements of the Uniform Guidance and understand the special test and provisions principal requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Finding No. 2021-009 Federal Agency: U.S. Department of Education CFDA Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Test and Provisions Questioned Cost: $0 Criteria: 34 CFR 685.300(a)(5) requires institutions to reconcile School Account Statements received from the U.S. Department of Education?s Common Origination and Disbursement System. Condition: The University did not have internal controls to maintain borrowers? data and perform the required reconciliation. Cause: The University?s management is not experienced with some of the requirements of the title IV funds. In addition, this is the University?s first Uniform Guidance audit which identified some of their non-compliance. Effect: The University is noncompliant with the requirements of the special test and provisions principal. Recommendation: The University?s management should review the requirements of the Code of Federal Regulations and Uniform Guidance to comply with the special test and provisions principal requirements. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.

Finding No. 2021-010 Federal Agency: U.S. Department of Education CFDA Number and Title: Student Financial Aid (SFA) Cluster Award Number: Various Area: Special Test and Provisions Questioned Cost: $0 Criteria: 34 CFR 690.83(b)(2) states that an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During test of details of the enrollment reporting, we noted that the NSLDS has recently updated their system that prevented the University from generating a report identifying the submission dates of the enrollment reports. Cause: NSLDS updated their system that prevented the University from generating a report identifying the submission dates of the enrollment reports. In addition, the University does not maintain their separate records of enrollment report submissions. Effect: We were unable to obtain sufficient, appropriate audit evidence supporting the University?s compliance with the requirement. Recommendation: The University should maintain their own records on when such reports are submitted. Views of responsible officials: Management agrees. Refer to Corrective Action Plan.