Open Recommendations

We recommend that the Chief Operating Officer for FSA, in conjunction with the Commissioner for NCES, require SNHU to update its policies and procedures for collecting, verifying, and reporting accurate data for the Graduation Rates survey to align with current IPEDS reporting requirements and ensure accurate classification of first-time, full-time undergraduate students seeking their first postsecondary education degree or certificate.

We also recommend the Chief Operating Officer for FSA consider taking appropriate action pursuant to subpart G of 34 C.F.R. 668 because the school reported inaccurate and incorrect information to IPEDS through the Graduation Rates survey for the 2021–2022 reporting period.

We recommend that the Chief Operating Officer for FSA, in conjunction with the Commissioner for NCES, require SNHU to update its existing policies and procedures to ensure that the cost of attendance data reported for the IPEDS Institutional Characteristics survey are accurate and supported by source documentation.

Ensure that financial reporting control activities require documentation to evidence management’s analysis of accounting updates, planned changes and rationale for such changes, and management’s review and approval of any planned accounting updates.

Perform ongoing monitoring of anticipated accounting changes and communicate potential updates to relevant stakeholders.

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We recommend that EXIM design, document, and implement controls to ensure [language withheld based on applicable Freedom of Information Act exemptions] that logical access is restricted to only authorized users.

Update its annual retrospective review through a grant recipient survey, review of invoice documentation, and/or other means for a lookback period greater than 4 months to analyze the results of the prior year accrual and determine if the 4-month lookback period remains sufficient to validate the grant accrual methodology in subsequent periods.

Analyze the reasons for the changes in the calculated average billing cycle and grant recipient billing patterns in recent periods and document the impact on its grant accrual methodology as part of its annual retrospective review prior to year-end.

Design and implement procedures to document the analysis performed to support any future changes to the grant accrual methodology prior to implementing such changes.