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4. Federal Requirements

Federal Requirement:

4.7 The institution is in compliance with its program responsibilities under Title IV of the most recent Higher Education Act as amended. (In reviewing the institution's compliance with these program responsibilities, the Commission relies on documentation forwarded to it by the U.S. Department of Education.) (Title IV program responsibilities)

Statement of Compliance:   In Compliance.

Narrative:

The University of West Georgia (UWG) is one of thirty-five (35) state-supported member institutions of higher education in Georgia which comprise the University System of Georgia, an agency of the State of Georgia.  The Board of Regents has constitutional authority to govern, control and manage the University System of Georgia.  As a member institution of the University System of Georgia, UWG is considered an organizational unit of the Board of Regents of the University System of Georgia for financial reporting purposes.

The Georgia Department of Audits and Accounts (DOAA) is responsible for auditing the financial statements on an annual basis for all Georgia state agencies, including University of West Georgia (UWG).  The O.C.G.A.  50-6-6 article states:

 “(a) It shall be the duty of the Department of Audits and Accounts thoroughly to audit and check the books and accounts of the county superintendents of schools and treasurers of local school systems, of municipal systems, of the several units of the University System of Georgia, and of all other schools receiving state aid and making regular and annual reports to the State School Superintendent, showing the amount received, for what purpose received, and for what purposes expended. All such funds held by officials must be kept in banks separate from their individual bank accounts

 (b) Notwithstanding any other provisions of this chapter, the local boards of education of the several county, independent, and area public school systems of this state shall be authorized to have an additional audit made of the books, records, and accounts of the public school system over which any such board has jurisdiction. The local boards of education shall be authorized to employ certified public accountants of this state to make the audits and to expend funds for the audits which are received by any such board for educational purposes.  (c) All audits of such public school systems shall be conducted in conformity with generally accepted standards and principles of governmental accounting and auditing and shall be subject to the standards, rules, and ethics promulgated by the Georgia Society of Certified Public Accountants and the American Institute of Certified Public Accountants. The audit report shall include the auditor's unqualified opinion upon the presentation of the financial position and the results of the operations of the public school system which is audited. If the auditor is unable to express an unqualified opinion, he shall so state and shall further detail the reasons for qualification or disclaimer of opinion including recommendations necessary to make possible future unqualified opinions” ” (extracted from the following website:http://www.lexisnexis.com/hottopics/gacode/).

In addition to providing an opinion on the financial statements, the DOAA also provides a report on internal control over financial reporting and compliance with rules and regulations as required by Government Auditing Standards.

The DOAA is also responsible for auditing the University’s financial aid programs per the requirements of the Single Audit Act of 1996 and the provisions of the Office of Management and Budget Circular A-133, “Audits of States, Local Governments, and Non-Profit Organizations.” Each year, the DOAA issues a comprehensive Single Audit Report for the University System of Georgia and UWG. Any audit findings that pertain to UWG in the Single Audit report are also included in the DOAA financial statement audit report.

Institutions of the University System of Georgia are audited regularly not only by DOAA and federal auditors, but by the Board of Regents (BOR) Internal Audit department.  The USG Internal Audit function exists to support the Board of Regents and local institution administrations in the effective discharge of their responsibilities.  Using knowledge and professional judgment, Internal Audit provides an independent appraisal of financial, operational, and control activities.  Auditors report on the adequacy of internal controls, the accuracy and propriety of transactions, the extent to which assets are accounted for and safeguarded, and compliance with institutional policies and government laws and regulations.  Additionally, Internal Audit is responsible for providing analysis, recommendations, counsel, and information concerning the activities reviewed.  To accomplish these objectives, an internal auditor is authorized to have full, free, and unrestricted access to all property, personnel, and records.  The International Standards for the Professional Practice of Internal Auditing published by the Institute of Internal Auditors, Inc. and “College and University Business Administration” published by the National Association of College and University Business Officers (NACUBO) shall serve as guidelines for internal audit activities.

The University’s response to audit findings is included in each audit report.

The annual Georgia Single Audit Reports for fiscal years ending June 30, 2009 [1], June 30, 2010 [2], June 30, 2011 [3], and June 30, 2012 [4] reveal no significant internal control weaknesses.  University of West Georgia receives Federal financial aid funds via electronic transfer and has not been obligated to post a letter of credit on behalf of the U.S. Department of Education.

A new financial aid director joined the university in April 2013 and quickly discovered a discrepancy between the university’s Satisfactory Academic Progress (SAP) policy for financial aid and the federal SAP regulations which changed due to the Program Integrity Regulations of October 29, 2010 with implementation by Fall 2011.  University administration quickly described the situation to the US Department of Education (ED) and has been working with ED since July 2, 2013 in analyzing data regarding this situation.  A new institutional SAP policy that meets federal requirements has been written and implemented effective with the Summer 2013 semester.  Complete resolution of this situation is anticipated by December 1, 2013.

Supporting Documentation: