Whitworth University

Finding 2022-001 ? COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds - Quarterly Reporting (Student Grants Portion) Federal Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.425E Federal Award Number: P425E200445 Federal Award Year: June 30, 2022 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly and annual reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4). The reporting requirements specify for the student portion the required items to be disclosed include the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. . Condition/Context: The auditor noted from reviewing the University?s student portion reports posted on the website that the estimated total number of students eligible to receive emergency financial aid grants was not disclosed as required. Questioned Costs: Not applicable. Cause: The University inadvertently omitted this required item in the reporting posted to the University?s website. Effect: The University was not in compliance with the HEERF student portion quarterly reporting requirements. Recommendation: The University should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management?s Response: The University strove to strictly follow all federal guidance in the administration of HEERF Funds and voluntarily chose to report awarded grants more often than required to illustrate the consistent access students had to the intended funds. The University listed the number of students receiving grants, but did not explicitly indicate the number of students who were considered eligible. The University has since updated the reporting webpages to clearly meet the specific federal requirement for disclosure of the estimated total number of students eligible. Going forward when presenting data and information related to federal funding, the University will use the exact vocabulary for all specified populations as suggested by the department of education. Further, all HEERF funds have been expended by the University and reporting has concluded. Therefore, no additional administrative revisions to the processes are required and the University considers this issue completely resolved.

Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition/Context: For two of 25 students included in our sample, the students withdrew from the University prior to meeting the graduation requirements. At that time, which was prior to 2020, the students were properly reported to the National Student Loan Data System (NSLDS) with the status of withdrawn. The students subsequently completed the final graduation requirements at different institutions and transferred the credits back to the University. In February and March 2020, it was determined that the students met all the requirements for graduation, however the status of graduated was not reflected in the NSLDS until September 2020. The sample was not a statistically valid sample. Cause: The University sends its enrollment reporting through a servicer, National Student Clearinghouse (NSC) to then be updated in NSLDS. The University's procedures for reporting when the statuses of previously withdrawn students changed did not allow for proper reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an Institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned costs: Not applicable Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and enrollment statuses are reported to NSLDS within the required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates and enrollment statuses reported to NSLDS to make sure they are accurate. Management?s Response: The University agrees with the finding and has designed and implemented certain steps to prevent and detect furture findings.

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