OUR LADY OF THE LAKE UNIVERSITY OF SAN ANTONIO

Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Management is responsible for compliance with Special Tests and Provisions – Enrollment Reporting procedures in accordance with the Uniform Guidance. (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309) Condition: Federal regulations provide that the University is responsible for notifying the National Student Loan Data System (NSLDS) of enrollment change. NSLDS was not notified timely, and the University’s internal control system did not prevent or detect that the NSLDS was not notified timely of the change. Questioned Costs: None Context: Out of a population of 388 students with enrollment changes, a sample of 25 students were selected for testing. 5 out of the 25 enrollment changes did not get reported timely to NSLDS. Our sampling method was not, and was not intended to be, statistically valid. Effect: The failure to timely report enrollment changes to NSLDS may result in inaccurate or delayed updates to student loan records. Cause: The University’s processes did not ensure that enrollment status changes were completed accurately and timely to NSLDS. Report Finding: No Recommendation: We recommend the University evaluate controls around monitoring enrollment reporting, ensuring NSLDS receives notification of enrollment changes. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.

Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Award No. PP031S220202-23 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Special Test - Key Personnel-Applications/proposals or awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. The nonfederal entity may change the staffing mix and level of involvement within limits specified by agency policy or in the award, but may be required to obtain federal awarding agency approval of changes in key personnel (as identified in the award, which may differ from the nonfederal entity’s designation in the application/proposal) and changes in the project director’s time commitment/level of participation in the project (OMB Circular A-110 §§_.25(c)(2) and (3)/2 CFR Sections 200.308(b)(2) and (3)). Condition: Federal regulations provide that the University is responsible for ensuring the staffing mix and level of involvement is within limits specified by agency policy or in the award, and to obtain federal awarding agency approval of changes in key personnel. The University’s internal control system did not prevent or detect that key personnel did not complete personal activity reports to support their involvement in the project as required. Questioned Costs: None Context: Out of a population of 13 key personnel assigned to the grants, a sample of four key personnel were selected for testing. One out of the four key personnel did not have formal documentation related to charging their time to the project. Our sampling method was not, and was not intended to be, statistically valid. Effect: Management failed to perform effective control activities to appropriately reduce the risk of noncompliance related to the key personnel special test during the fiscal year. The lack of an adequate control environment over this special test requirement could result in personnel being involved in projects utilizing federal funds that have not been properly approved by the granting agency. Cause: The University’s processes did not ensure that key personnel were properly involved in projects under the Research and Development Cluster. Report Finding: No Recommendation: We recommend the University strengthen its processes and controls to help ensure that all key personnel involved in projects under the Research and Development Cluster are properly approved and involved in grant project objectives. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.

Federal Program – Student Financial Assistance Cluster Assistance Listing No. 84.268 U.S. Department of Education Program Year 2022–2023 Criteria or Specific Requirement – Direct Loan Reconciliation CFR 685.300 Condition – The University’s failed to complete required direct loan reconciliations during the 2022–2023 aid year. The University is responsible for reconcilng University disbursement data to the Department of Education’s Common Origination and Disbursement System on a monthly basis and for establishing internal controls to ensure that such reconciliations are completed within federal requirements. Questioned Costs – N/A Context – Out of a population of 12 months, two months were selected for testing. No support for the monthly reconcilations for these months was able to be provided, and it was noted that reconcilations did not take place for any months during the year ended May 31, 2023. Our sample was not, and was not intended to be, statistically valid. Effect – The University failed to complete monthly reconcilations as required and could have had errors in direct loans that were not identified. Cause – The University experienced turnover and decreased staffing levels during the year. Identification as a Repeat Finding, if Applicable – N/A Recommendation – The University should put controls in place to ensure that reconcilations are being completed on a monthly basis as required. Corrective Action Plan – OLLU has already begun coordinating processes between its Accounting and Financial Aid departments to download the monthly SAS into the University’s system electronically, where Accounting will then reconcile the statement monthly as part of its month-end close procedures. The Financial Aid Director will be responsible for ensuring that the statement is downloaded monthly as a part of the regular electronic data file transfer between OLLU and the Department of Education. The Senior Accountant in the Accounting Department will generate the report in Colleague via the DRSS process and reconcile the SAS statement to cash records. The Director of Accounting and Reporting will review the reconciliation monthly. Anticipated Completion Date – February 15, 2024