University of West Georgia, Carrollton, Georgia, independent accountant's report on applying agreed-upon procedures for the fiscal year ended 2019 June 30

UNIVERSITY OF WEST GEORGIA
CARROLLTON, GEORGIA
INDEPENDENT ACCOUNTANT'S REPORT ON APPLYING AGREEDUPON PROCEDURES FOR FISCAL YEAR ENDED JUNE 30, 2019
A Member Institution of the University System of Georgia

UNIVERSITY OF WEST GEORGIA - TABLE OF CONTENTS -
INDEPENDENT ACCOUNTANT'S REPORT ON APPLYING AGREED-UPON PROCEDURES SCHEDULE OF FINDINGS AND QUESTIONED COSTS SCHEDULE OF MANAGEMENT'S CORRECTIVE ACTION

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GREG S. GRIFFIN
STATE AUDITOR
(404) 656-2174

DEPARTMENT OF AUDITS AND ACCOUNTS
270 Washington Street, S.W., Suite 1-156 Atlanta, Georgia 30334-8400

Independent Accountant's Report on Applying Agreed-Upon Procedures
Members of the State Board of Regents of the University System of Georgia
and Dr. Michael Crafton, Interim President University of West Georgia
Ladies and Gentlemen:
We have performed the procedures enumerated below, which were agreed to by University of West Georgia and the University System Office of the Board of Regents of the University System of Georgia, solely to assist you in evaluating compliance with federal student financial assistance regulations and meeting the requirements of COC Comprehensive Standard 13.6 for the year ended June 30, 2019. The sufficiency of these procedures is solely the responsibility of the parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. Also included in this report is a section on findings and other matters that came to our attention during our engagement.
The procedures for each Student Financial Assistance Cluster compliance requirement and the associated findings are as follows:
1. Complete applicable procedures reflected in the 2019 OMB Compliance Supplement for the Activities Allowed or Unallowed compliance requirement.
We did not note any exceptions as a result of our procedures.
2. Complete applicable procedures reflected in the 2019 OMB Compliance Supplement for the Cash Management compliance requirement.
We did not note any exceptions as a result of our procedures.
3. Complete applicable procedures reflected in the 2019 OMB Compliance Supplement for the Eligibility compliance requirement.
See FA-2019-001 and FA-2019-002 in the Schedule of Findings and Questioned Costs for a detail of exceptions noted.
4. Complete applicable procedures reflected in the 2019 OMB Compliance Supplement for the Matching, Level of Effort, Earmarking compliance requirement.
We did not note any exceptions as a result of our procedures.

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5. Complete applicable procedures reflected in the 2019 OMB Compliance Supplement for the Reporting compliance requirement.
We did not note any exceptions as a result of our procedures.
6. Complete applicable procedures reflected in the 2019 OMB Compliance Supplement for the Special Tests and Provisions compliance requirement.
See FA-2019-003 in the Schedule of Findings and Questioned Costs for a detail of exceptions noted.
This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. We were not engaged to and did not conduct an examination or review, the objective of which is to express an opinion or conclusion, respectively, on the Federal Student Aid compliance requirements. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.
This report is intended solely for the information and use of University of West Georgia, the University System Office of the Board of Regents of the University System of Georgia and the Southern Association of Colleges and Schools Commission on Colleges and is not intended to be, and should not be, used by anyone other than these specified parties.
Respectfully,

January 27, 2020

Greg S. Griffin State Auditor

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UNIVERSITY OF WEST GEORGIA SCHEDULE OF FINDINGS AND QUESTIONED COSTS
YEAR ENDED JUNE 30, 2019

FEDERAL AWARD FINDINGS AND QUESTIONED COSTS

FA-2019-001

Strengthen Controls over the Awarding Process

Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: CFDA Numbers and Titles:
Federal Award Numbers:
Questioned Costs:

Eligibility Significant Deficiency Nonmaterial Noncompliance U. S. Department of Education None 84.007 Federal Supplement Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Program 93.264 Nurse Faculty Loan Program P007A181059 (Year: 2019), P033A181059 (Year: 2019), P063P180095 (Year: 2019), P268K190095 (Year: 2019), E01HP28790-05-00 (Year: 2019) $1,524.00

Description: The Institution's Student Financial Assistance Office improperly determined the Student Financial Assistance award amounts for eligible students.

Criteria: Provisions included in 34 CFR 668 provide general provisions for administering Student Financial Assistance (SFA) programs and 34 CFR 675, 676, 685, and 690 provide eligibility and other related program requirements that are specific to the Federal Work-Study Program, Federal Supplemental Educational Opportunity Grant (FSEOG) Program, Federal Direct Student Loans Program, and Federal Pell Grant Program, respectively. In addition, provisions included in 42 CFR 57 provide eligibility and other related program requirements that are specific to the Nursing Student Loans Program.

Condition: A sample of 25 students who received student financial assistance funds was randomly selected for testing using a non-statistical sampling method. Student financial assistance files were reviewed to ensure that financial assistance was properly calculated and disbursed to eligible students. Testing revealed that one student received $1,524.00 more in Federal Pell Grant funds than they were eligible to receive based upon their enrollment status and Expected Family Contribution (EFC).

Questioned Costs: Questioned costs of $1,524.00, with likely questioned costs of $518,915.92, were identified for the student who received student financial assistance in excess of their eligibility. The following CFDA number is affected by the known and likely questioned costs: 84.063.

Cause: In discussing this deficiency with management, they stated that the student was awarded aid for the 1819 award year prior to the change of status during the Spring 2019 semester. The student dropped classes at the beginning of the Spring 2019 semester and their Federal Pell Grant award for the 1819 award year was not revised to reflect the effect of the change.

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UNIVERSITY OF WEST GEORGIA SCHEDULE OF FINDINGS AND QUESTIONED COSTS
YEAR ENDED JUNE 30, 2019

FEDERAL AWARD FINDINGS AND QUESTIONED COSTS
Effect or Potential Effect: This deficiency may expose the Institution to unnecessary financial strains and shortages. The funds disbursed to students in excess of their eligibility must be returned to the U.S. Department of Education. Though the Institution may attempt to collect the funds from individual students affected by the error, these collection efforts could be unsuccessful as the students may no longer attend the Institution and/or fail to repay the funds. Additionally, the Institution was not in compliance with Federal regulations concerning awarding of SFA funds to students.
Recommendation: The Institution should review its processes and procedures for determining each student's financial aid eligibility. Where vulnerable, the Institution should develop and/or modify its policies and procedures to ensure that correct amounts will be awarded to students in conformity with Federal requirements. Additionally, the Institution should develop and implement a monitoring process to ensure that controls are functioning properly. The Institution should also contact the U.S. Department of Education regarding resolution of this finding.
Views of Responsible Officials: We concur with this finding.

FA-2019-002

Improve Controls over Cost of Attendance Budgets

Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: CFDA Numbers and Titles:
Federal Award Numbers:
Questioned Cost:

Eligibility Significant Deficiency Nonmaterial Noncompliance U. S. Department of Education None 84.007 Federal Supplement Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Program 93.264 Nurse Faculty Loan Program P007A181059 (Year: 2019), P033A181059 (Year: 2019), P063P180095 (Year: 2019), P268K190095 (Year: 2019), E01HP28790-05-00 (Year: 2019) None Identified

Description: The Institution's Student Financial Aid Office did not document the procedures used to establish Cost of Attendance (COA) budgets.

Criteria: Provisions included in 34 CFR 668 provide general provisions for administering Student Financial Aid (SFA) programs. In addition, Section 472 of the Higher Education Act of 1965 specifies the components that can be included in COA budgets.

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UNIVERSITY OF WEST GEORGIA SCHEDULE OF FINDINGS AND QUESTIONED COSTS
YEAR ENDED JUNE 30, 2019

FEDERAL AWARD FINDINGS AND QUESTIONED COSTS
Condition: Upon review of the Institution's COA budgets, it was noted that Institution personnel could not provide supporting documentation or explanations for the calculation of the components of the COA budgets, including Books and Supplies, Personal Expenses, Room and Board, Tuition and Fees, Transportation, and Loan Fees.
Cause: In discussing these deficiencies with management, they stated that supporting documentation for the COA budgets could not be located for review due to turnover within the SFA Office.
Effect or Potential Effect: The Institution was not in compliance with Federal regulations concerning the COA budgets used as the basis for determining SFA eligibility. The COA is the cornerstone of establishing a student's financial need and sets a limit on the total aid a student may receive. If the estimated costs used for components in the COA budget are unreasonable and do not represent average costs for students at the Institution, a majority of the student population may have been over or under awarded.
Recommendation: The Institution should reevaluate the components used in the COA budgets and document that these costs represent average costs for students enrolled at the Institution. The Institution should modify its procedures to ensure that any future changes to the COA budgets are reasonable and based on documented average costs for students. The Institution should also contact the U.S. Department of Education regarding resolution of this finding.
Views of Responsible Officials: We concur with this finding.

FA-2019-003

Improve Controls over the Return of Title IV Funds Process

Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: CFDA Numbers and Titles:
Federal Award Numbers:
Questioned Costs:

Special Tests and Provisions Significant Deficiency Nonmaterial Noncompliance U. S. Department of Education None 84.007 Federal Supplement Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Program 93.264 Nursing Student Loans P007A181059 (Year: 2019), P033A181059 (Year: 2019), P063P180095 (Year: 2019), P268K190095 (Year: 2019), E01HP28790-05-00 (Year: 2019) $879.83

Description: The Institution did not properly perform the refund process to ensure that unearned Title IV funds were returned in a timely manner.

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UNIVERSITY OF WEST GEORGIA SCHEDULE OF FINDINGS AND QUESTIONED COSTS
YEAR ENDED JUNE 30, 2019
FEDERAL AWARD FINDINGS AND QUESTIONED COSTS
Criteria: Provisions included in 34 CFR 668.22 provide requirements over the treatment of Title IV funds when a student withdraws. The Institution is required to determine the amount of Title IV funds that the student earned as of the student's withdrawal date when a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. A refund must be returned to Title IV programs when the total amount of the Title IV grant or loan assistance, or both, that the student earned is less than the amount of the Title IV grant or loan assistance that was disbursed to the student as of the withdrawal date.
Condition: A sample of 40 students who received student financial assistance (SFA) for the Fall 2018 and Spring 2019 semesters and withdrew from the Institution was randomly selected for testing using a non-statistical sampling method. The students' Return of Title IV calculations were reviewed to ensure that the refunds were calculated and returned in the correct amount to the proper funding agency and/or student in a timely manner. The following deficiencies were noted:
The refund calculation for one student who withdrew during the Fall 2018 semester and four students who withdrew during the Spring 2019 semester was calculated incorrectly due to the use of improper scheduled break days, withdrawal dates, and/or institutional charges. Three students were requested to return $879.83 less than the required amount to various SFA programs, and two students were requested to return $5,174.49 more than the required amount to various SFA programs.
The proration between the school and student portion of the refund was incorrect for two students who withdrew during the Fall 2018 semester and eight students who withdrew during the Spring 2019 semester.
Questioned Costs: Questioned costs of $879.83, with likely questioned costs of $6,433.70, were identified for refunds calculated incorrectly. The following CFDA numbers are affected by the known and likely questioned costs: 84.063 and 84.268.
Cause: In discussing these deficiencies with management, they stated that they misunderstood the process of prorating the institutional charges when students withdraw. In addition, human errors occurred when entering data into the manual calculations.
Effect or Potential Effect: This deficiency may expose the Institution to unnecessary financial strains and shortages. The Institution's portion of the refunds that were not calculated correctly must be returned to the U.S. Department of Education. Though the Institution may attempt to collect the funds from individual students affected by the error, these collection efforts could be unsuccessful as the students may no longer attend the Institution and/or fail to repay the funds. Additionally, the Institution was not in compliance with Federal regulations concerning performing Return of Title IV calculations for withdrawn students.
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UNIVERSITY OF WEST GEORGIA SCHEDULE OF FINDINGS AND QUESTIONED COSTS
YEAR ENDED JUNE 30, 2019 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Recommendation: The Institution should revise and implement procedures to ensure that student financial aid refunds are properly calculated and that unearned funds are correctly returned to the appropriate accounts in a timely manner in accordance with the Higher Education Amendments 1998, Public Law 105-244. The Institution should also contact the U.S. Department of Education regarding resolution of the finding. Views of Responsible Officials: We concur with this finding.
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