Brigham Young UniversityHigher Education

Reference Number 2025‐001 ‐ Special Test – National Student Loan Data System (NSLDS) Reporting Federal Program and Assistance Listing Number (ALN) —Various Criteria ‐ Institutions participating in Title IV programs (e.g., Pell Grant, Direct Loan) must timely and accurately report student enrollment information to the NSLDS. This is required per the NSLDS Enrollment Reporting Guide and applicable federal regulations (Pell, 34 CFR 690.83(b)(2); and Direct Loan, 34 CFR 685.309). Institutions must review, update, and certify enrollment status and program-level information using the NSLDS Enrollment Reporting Roster or the NSLDS Enrollment Maintenance page. Accurate reporting ensures the administration of Title IV aid, impacts student loan servicing, and maintains compliance with federal requirements. Statement of Condition ‐ During our testing, we selected a sample of 40 students who had changes in their enrollment status during the academic year, two students were identified to have enrollment changes not reported to NSLDS in accordance with the requirements. Questioned Costs ‐ None Effect ‐ The University did not report changes in student enrollment data accurately to the NSLDS. Underlying Cause ‐ This was caused by a misunderstanding of NSLDS reporting requirements for students enrolled at least half-time in a non-required spring/summer term who later withdrew or dropped to below less-than-half-time status. The University reverted affected students to their most recently certified Winter 2025 enrollment status, rather than retaining the most recent spring/summer status of half-time or greater through the remainder of the term in NSLDS. Recommendation – The University should ensure that reporting of enrollment changes to the NSLDS is performed accurately in accordance with the OMB regulations.

Reference Number 2024-001 - Procurement Expenditures within Research and Development Cluster Federal Program and Assistance Listing Number (ALN) —Various Criteria ‐ In accordance with 2 CFR Part 200 for Procurement, small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Further, in accordance with Brigham Young University’s procurement policy, a strategic sourcing specialist must obtain at least two competitive quotes for expenditures between $10,000 and $250,000. Statement of Condition ‐ During our testing, we selected a sample of 12 procurements from a population of 41 total procurements. Of the sample of 12 procurements, 5 sampled procurements did not obtain at least two competitive quotes for expenditures. Questioned Costs ‐ None Effect ‐ The University did not comply with their procurement policy or the Compliance Supplement – May 2024 (2 CFR Part 200, Appendix XI) by obtaining competitive quotes for expenditures. Underlying Cause ‐ University grant officials did not sufficiently review and track procurement expenditures to ensure that the competitive quotes were received and that the University’s policy was being followed. Recommendation – The University should ensure all strategic sourcing specialists receive training on the University’s policy regarding procurement expenditures. Further, the University should perform regular reviews to ensure its existing policies and procedures are being followed. Management’s View and Corrective Action Plan ‐ Management agrees with the finding and will provide policy training to the individuals and teams involved in the grant procurement process beginning in the second quarter of 2025. New employee training will emphasize these policies. In addition, regular self-reviews will be performed to confirm policy adherence beginning in the third quarter of 2025.