NAROPA UNIVERSITY

2022-002 U.S. Department of Education Financial Assistance Listing No. 84.425E, 84.425F, and 84.425M COVID-19 ? Higher Education Emergency Relief Funds ? Student, COVID-19 ? Higher Education Emergency Relief Funds ? Institutional, and COVID-19 ? Strengthening Institutions Program Procurement, Suspension, and Debarment Significant Deficiency in Internal Control Criteria: Entities expending federal monies are required to have a written procurement policy that is compliance with Uniform Guidance, 2 CFR Section 200.318-327. Condition: While the University does have a written compliance policy, elements that are required by Uniform Guidance, 2 CFR Section 200.318-327, are missing from the written policy. Cause: The University previously had not received federal awards, other than Student Financial Assistance monies. As a result, they did not have a written procurement policy in place. Management worked on creating a policy in the prior fiscal year, however the policy does not include all the required elements. Effect: The University?s written procurement policy is not compliant with Uniform Guidance, 2 CFR Section 200.318-327. Questioned Costs: None. Context/Sampling: HEERF was not selected as a major program in the current year, as such no sampling occurred. The Auditor obtained a copy of the newly written procurement policy to test the policy?s compliance with Uniform Guidance. Repeat Finding from Prior Year(s): Yes, finding 2021-003 Recommendation: Management should review their procurement policy in combination with the language of Uniform Guidance, 2 CFR Section 200.318-327, to ensure the required elements from the guidance are included in the written procurement policy. Views of Responsible Officials: Management agrees with the finding.

CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster (Pell - 84.063 and Federal Direct Loans - 84.268) Federal Award Identification Number and Year - 2021 - 84.063 and 84.268 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2020-002, 2019-001 Criteria - The University has 60 days from the date it determines an enrollment status change to report to NSLDS. The enrollment reporting must be updated for changes in the data elements for the campus record and the program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition - Of the 40 students selected for enrollment reporting testing, the University did not properly update student enrollment information for 6 students in an accurate or timely manner. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Out of a sample of 40 students, we noted 6 students whose graduations were not timely reported. Cause and Effect - A control was lacking to ensure information submitted to National Student Clearinghouse was completed accurately and timely. As a result, 6 student status changes were reported late. Recommendation - The University should implement a process to ensure that all student status changes are reported to NSLDS in an accurate and timely fashion. Views of Responsible Officials and Corrective Action Plan - While Naropa University (NU) has made tremendous progress over the past few years in relation to NSLDS reporting, the University is continually reviewing processes and procedures, implementing new controls, and identifying new opportunities to improve the NSLDS reporting process. NU is actively recruiting an additional staff member in the registration department whose primary responsibility is ensuring accurate and timely NSLDS reporting and data integrity across university systems. NU planned to staff this position during the last fiscal year; however, this proved difficult, as there were key leadership changes and, like many higher education institutions, NU faced a staffing crisis, struggling to recruit qualified professionals into open positions. Given the complications NU has encountered with reporting through NSC, it continues to explore moving away from NSC for enrollment and graduation reporting. While this is being explored, NU will manually report each graduation and withdrawn student in NSLDS to ensure timely reporting. NU is also implementing additional controls for the monthly enrollment reporting batches submitted, with an enhanced review process for each record and data point, to confirm data integrity and reduce batch errors. Once the monthly enrollment reporting batches are submitted, there will be an internal sampling of those records reviewed in NSLDS for quality assurance, confirming accuracy of the data reported and timely processing of the batches. If it is found there is a delay in the batch that may result in untimely reporting, the entire batch will be manually updated directly in NSLDS to prevent untimely reporting. NU is committed to addressing NSLDS reporting issues and improving policies and procedures to guarantee compliance.

CFDA Number, Federal Agency, and Program Name - COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund - CFDA 84.425F Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The University is required to have a procurement policy in place when making purchases using federal funds that is in compliance with Uniform Guidance, 2 CFR Section 200.318-327. Condition - The University does not have a policy in place the complies with 2 CFR Section 200.318-327. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - A sample of 38 allowable cost transactions were selected; however, none followed a Uniform Guidance procurement policy. Cause and Effect - Due to not receiving federal grants other than Student Financial Assistance Cluster in the past, the University never developed a policy in compliance with Uniform Guidance. As a result, transactions occurred without following Uniform Guidance procurement standards. Recommendation - The University should develop a procurement policy that aligns with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions - Naropa University agrees with the auditor?s finding. The business affairs division has drafted a purchasing policy that conforms to federal regulations and will submit it to the finance and sustainability committee at the February 17, 2023 meeting for review and confirmation.

CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster (Pell-84.063 and Federal Direct Loans- 84.268) Federal Award Identification Number and Year - 2020 - 84.063 and 84.268 Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2019-001 Criteria - The University has 60 days from the date the University determines an enrollment status change to report to NSLDS. The enrollment reporting must be updated for changes in the data elements for the campus record and the program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition - Of the 25 students selected for enrollment reporting testing, the University did not properly update student enrollment information for 10 students in an accurate or timely manner. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Out of a sample of 25 students, we noted 10 who were not accurately or timely reported as follows - 8 of 10 received degrees after final semester reporting, but this was not reported until after the required reporting window; 2 of 10 officially withdrew, and this was not reported timely due to an error with the data upload. Cause and Effect - The University adds the required information for graduates and withdrawals to a third party system to report the appropriate enrollment information. During 2020, the University did not review the third party upload after completion, which led to the delayed reporting to NSLDS. Recommendation - The University should consider implementing a process to submit a final enrollment file upon completion of processing semester graduates, adopting a policy on consistent reporting of unofficial withdrawals, and reviewing procedures to verify that the information uploaded and reported is complete, accurate, and timely. Views of Responsible Officials and Corrective Action Plan - The University has identified several reporting issues found in the system interfaces between Naropa University, the National Student Clearinghouse, and NSLDS that have contributed to creating the condition noted above. Naropa University will implement the following to address these issues: ? Assign staff to increase the monitoring controls after submission to ensure timely reporting, including manual reporting when necessary. The University is exploring alternate options for reporting, including moving away from the National Student Clearinghouse. ? The Registrar?s Office will implement a weekly review of enrollment changes that have been processed that affect enrollment status and where necessary manually update the NSLDS system. ? The University has been working to incorporate the reporting of delayed graduations into the monthly enrollment reporting system. Until this system is processing correctly, delayed graduations will be transitioned to manual reporting for those students to ensure timely reporting.

Criteria - In relation to the Pell Grant Program, 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. In relation to the Financial Direct Student Loan Program, student status confirmation reports shall be completed and returned to the secretary within 30 days of receipt. In addition, unless the institution expects to submit its next student status confirmation report to the secretary within the next 60 days, the institution must notify the secretary within 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who has ceased to be enrolled on at least a half-time basis, has been accepted for enrollment at that school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address (34 CFR section 685.309 and 34 CFR part 668). Condition - Audit testing identified one student whose status was not timely reported as graduated per the National Student Loan Data System (NSLDS).Context - Out of a sample of 25 students, our testing identified one error related to a student who completed graduation requirements in the semester after the student's graduation date. In this instance, the student's status was timely updated to withdrawn but was not timely updated to graduated once requirements were completed. As a result, the student status change is not being updated timely on NSLDS for students who complete graduation requirements after their graduation date.Cause and Effect -The University did not have the proper procedures to identify students who completed their graduation requirements. Untimely or inaccurate status change reporting could affect a student's ability to receive aid or enter a repayment period or other transactions that rely on enrollment status being correctly reported to NSLDS. Recommendation - The University should implement controls to identify any students who complete requirements subsequent to their graduation date. For any students identified, the University should either manually update each student who met this criteria and received a degree without re-enrolling or consider re-enrolling for accurate and timely status update. Views of Responsible Officials and Corrective Action Plan - The Office of Student Financial Services will evaluate the most effective method in which to ensure timely reporting of student enrollment status, including auditing of Clearinghouse/NSLDS data and/or reporting directly to NSLDS.