Western New Mexico UniversityHigher Education

During our test work of internal controls over reporting requirements with the National Student Loan Data System (NSLDS), we noted the following instance of non-compliance in sample of forty:One student did not attend the school in fiscal year 2025, but Clearing House reflects the status of the student as half time. - One student graduated on 5/8/25, but Clearing House reflects the status of the student as full time. - One student graduated on 7/24/24, but Clearing House reflects the status of the student as withdrawal. - One student graduated on 5/8/25, but Clearing House reflects the status of the student as full time.

The reporting package for the year ended June 30, 2024 was submitted after the required due date.

During our test work of internal controls over reporting requirements with the National Student Loan Data System (NSLDS), we noted the following instance of non-compliance in sample of forty-five: - One student graduated on 5/4/23, but Clearing House reflects the status of the student as full time.

During our test work of the reporting requirements, special reporting, we noted that the University did not prepare the quarterly reporting for the grant to the pass-through entity.

Condition Certain vendors were not screened using the federal System for Award Management (SAM) to verify that they had not been suspended or debarred. Instead, the New Mexico General Services Department debarment notice website was used to screen potential vendors. The New Mexico debarment list does not include all federally suspended or debarred entities. Criteria The Code of Federal Regulations, Title 2, Subtitle 2, Chapter 1, Part 180.220 prohibits non-federal entities like the University, from contracting with parties that are suspended or debarred when federal funds are involved. Cause The purchasing agent screened the potential vendors against an incomplete suspended and debarred database. Effect None of the vendors tested were suspended or debarred. Potentially, the University may have violated federal law by using a vendor that was suspended or debarred. Recommendation Ensure the all vendors are screened using the System for Award Management prior to approving a vendor. Response As part of the approval process for all purchases utilizing federal funds, the accounting and budget department will do a search for exclusions on the System for Award Management (SAM) website. Proof of the results will be attached to the requisition. The purchasing department will verify the search for exclusions was completed with acceptable results prior to processing the purchase requisition. Beginning November 1, 2022, the Director of Purchasing is responsible for verifying results of debarment on the System for Award Management website.

Funding Agency: US Department of Education ALN: 84.425 E, F, L Program: Higher Education Emergency Relief Fund (HEERF) Pass Through Entity ? N/A Condition During our test work of the reporting requirements, special reporting, we noted that the University prepared the fourth quarter report for the institutional portion and funds but did not publicly display the report timely. Two months after the end of the quarter, the report was not posted on the Universities website. The first three quarterly reports of the fiscal year were displayed timely on the University?s website. Criteria The institution must prepare reports each quarter that indicate how the CARES funds were spent. The forms are provided. These reports must be conspicuously posted on the institution?s primary website within 30 days of the end of the quarter. Cause The forms were prepared and submitted to the department responsible for updating the University?s website but there was no follow up to confirm that the reports had be uploaded. Effect The University was not in compliance with federal requirements regarding the public display of the quarterly reports. Recommendation Examine the University?s website before the end of the 30-day period to ensure that the reports have been properly posted. Response The task to verify the upload of required quarterly reports to the university?s website has been added to the quarterly closing checklist and will be verified by the director of accounting no later than 30 days after the end of the quarter. Beginning October 31, 2022, the Director of Accounting is responsible for verifying posting of required reports on the University?s website.

CONDITION: DURING OUR TESTWORK OF INTERNAL CONTROLS OVER RETURN OF TITLE IV FUNDS (R2T4), WE NOTED THE FOLLOWING INSTANCES OF NON-COMPLIANCE IN OUR SAMPLE OF FORTY. IN OUR SAMPLE OF FORTY, WE NOTED THREE INSTANCES TOTALING $286 IN WHICH TITLE IV FUNDS WERE NOT RETURNED WITHIN 45 DAYS AS REQUIRED. THE UNIVERSITY HAS MADE PROGRESS ON THIS FINDING. ALL INSTANCES IDENTIFIED ABOVE OCCURRED PRIOR TO THE UNIVERSITY IMPLEMENTING A NEW PROCESS WITHIN THEIR ACCOUNTING SYSTEM (BANNER) TO HELP CALCULATE AND RETURN TITLE IV FUNDS. QUESTIONED COSTS: NONE CAUSE: RETURNS WERE NOT REFUNDED AS REQUIRED. EFFECT: THE UNIVERSITY WAS NOT IN COMPLIANCE WITH FEDERAL REQUIREMENTS FOR THE RETURN OF TITLE IV FUNDS. RECOMMENDATION: THE UNIVERSITY SHOULD IMPLEMENT A THOROUGH REVIEW PROCESS FOR THE R2T4 FORMS AND THE CALCULATIONS NOW BEING COMPLETED WITHIN BANNER TO ENSURE THAT THE CALCULATED AMOUNT OF TITLE IV FUNDS TO BE RETURNED ARE PROCESSED TIMELY. VIEWS OF RESPONSIBLE OFFICIALS AND CORRECTIVE ACTION PLAN: THE OFFICE OF FINANCIAL AID HAS FULLY IMPLEMENTED THE RETURN TO TITLE IV PROCESS IN THE BANNER SYSTEM, WHICH AUTOMATES THE PROCESS TO ELIMINATE HUMAN ERROR. THE IMPLEMENTATION WAS COMPLETE ON NOVEMBER 12, 2019, AND ALL RETURNS WERE REVIEWED BY THE DIRECTOR OF FINANCIAL AID. IN DOING SO, THERE WERE A FEW RETURNS THAT WERE FOUND TO HAVE NOT BEEN PROCESSED TIMELY AND THEY WERE PROCESSED IMMEDIATELY; HOWEVER, THAT MADE THE RETURNS GREATER THAN THE ALLOWED 45 DAYS. THE UNIVERSITY WILL CONTINUE WITH ITS RETURN TO TITLE IV PROCESS IN THE BANNER SYSTEM WITH A REVIEW BY THE DIRECTOR OF FINANCIAL AID TWICE A SEMESTER.

Condition During our test work of internal controls over Return of Title IV Funds (R2T4), we noted the following instances of non-compliance in our sample of twenty-five. In our sample of twenty-five, we noted nine instances in which the amount of Title IV funds required to be returned were calculated incorrectly and/or not returned in the correct amount resulting in a net misstatement of approximately $7,000 of funds that should have been returned but were not. Of these nine, there were four instances in which no funds were returned to Title IV by the University. We also noted seven instances in which Title IV funds were not returned within 45 days as required. This area continues to be challenging for the University due to turnover in the position during the year. There continued to be noncompliance for R2T4. Questioned Costs It is difficult to determine the precise error in the entire population due to the variables regarding the amount of the aid accepted, the date of each student's withdrawal, and the amount required to be returned. As our sample represents approximately 21% of the population of students with Title IV fund returns, a basic extrapolation results in a likely questioned costs of $33,920, which exceeds the $25,000 questioned cost parameter. Criteria The institution must refund a percentage of the lesser of the total amount of unearned Title IV assistance or an amount equal to the total institutional charges incurred by the student, as calculated. Institutional charges include tuition, fees, room and board, if the student contracts with the institution for room and board [34CFR section 668.22(g)]. The calculated balance is required to be refunded to the DOE within 45 days of the date of the student's withdrawal. [34 CFR section 668.22(j)(l). Cause Returns were incorrectly calculated, not reported, and refunded as required. Effect The University was not in compliance with federal requirements for the return of Title IV funds; effectively underreporting the amount required to be refunded. Recommendation Review the procedures involving the calculation of R2T4 performed by the Student Financial Aid Office. The University should incorporate a thorough review process for the R2T4 forms to ensure that the calculated amount of Title IV funds to be returned is correct and that the returns are processed timely.

Condition During our test work of internal controls over financial aid eligibility, disbursements to/on behalf of students, and reporting of disbursements, we noted the following instances of non-compliance in our sample of forty. In our sample of forty, we noted three instances in which students were not making satisfactory academic progress and it appeared that the University?s Satisfactory Academic Progress policies were not followed. We noted one instance in which a master promissory note?s status within the University?s financial aid system was not active as of the date of the disbursement. We also noted one instance in which the University did not submit disbursement information to the Common Origination Department within 30 days as required. Criteria Students not making satisfactory academic progress are not eligible to receive federal financial aid as specified in 34 CFR 685.200(f). Disbursements made to/on behalf of students relevant to direct loans are required to have a signed master promissory note before the date of financial aid disbursement as required by 34 CFR 668.165 Reporting to the common origination department (COD) is required to be done within 15 days of the disbursement as required by OMB No. 1845-0021. Cause Satisfactory academic progress was not monitored appropriately by the financial aid department. Controls were in place relevant to disbursements to/on behalf of students and reporting disbursement information to the common origination department. Effect The University was not in compliance with federal requirements for eligibility, disbursements to/on behalf of students, and reporting to the common origination department; effectively over-awarding financial aid to ineligible students and failing to report disbursement information timely. Recommendation Review the procedures involving the monitoring of student eligibility for financial aid especially as it relates to monitoring of satisfactory academic progress, ensure that master promissory notes are signed and active as of the date of disbursement of funds, and ensure that reporting of information to the common origination department is done timely.

Condition During our test work of internal controls over verification, we noted the following instances of non-compliance in our sample of fifty-one. We noted two instances in which a household size and number of students in college was improperly identified by the Director of Financial Aid as compared to the verification worksheet in the students? financial aid files. We also found the University's written Financial Aid Verification Policy did not include the required student notifications. Criteria An institution shall require each applicant whose application is selected by the Department of Education to verify the information specified in 34 CFR Section 668.56. In addition, the College's Verification Policy states that as part of the verification process, household size and number of students in college must be verified and updated to match appropriate supporting documentation within financial aid systems. The College must follow written policies and procedures that incorporate the provisions of 34 CFR Sections 668.51 through 668.61 for verifying applicant information. Cause During the verification process, the Director of Financial Aid reviewed the verification worksheet and updated the financial aid software to reflect an incorrect household size based on a worksheet that included duplicated information in multiple sections of the form. Effect Students whose household sizes and number of students in college is stated as a number higher than actual could receive financial aid in excess of what they are actually eligible to receive. Policies and procedures in place could allow for verification requirements to be missed causing ineligible students to be awarded financial aid funds. Recommendation We recommend that the College correct the parameters for all verification types to ensure that all information required to be verified is verified properly and for the College to ensure that all required provisions of 34 CFR Sections 668.51 through 668.61 are included in the Verification Policy.

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