Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell
grant for an academic year is based upon the payment and disbursement schedule published by the
Secretary for each award year. The payment schedule takes into account the cost of attendance, the
student’s estimated family contribution (EFC) and the enrollment status of the student.
Condition: 1 of 40 students tested was under awarded and disbursed Pell grant funds.
Questioned costs: $450.
Context: An incorrect EFC was used to calculate the Pell award.
Cause: The student made changes to their Free Application for Federal Student Aid (FASFA) and the
University did not use the most updated version of the student’s FASFA.
Effect: A student was under awarded and disbursed Pell funds.
Repeat Finding: No.
Recommendation: We recommend that the University establish a process to review changes and
updates to a student’s FASFA prior to disbursing funds to ensure the most up to date and accurate
information is being used for Pell awards.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that
don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR
682.610).
Condition: Certain students’ enrollment information was not reported accurately to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following:
2 students out of a sample of 40 students tested were reported to the NSLDS with the incorrect
enrollment status on both the campus-level and program-level records in the NSLDS.
1 student out of a sample of 40 students had an enrollment effective date in the program-level
records that did not match what was reflected in the University’s records and the campus-level
record in the NSLDS.
8 students out of a sample of 40 students tested were not reported to the campus-level record in
the NSLDS in a timely manner.
2 students out of a sample of 40 students tested did not have their summer 2023 term
enrollment information reported to both the campus-level and program-level records in the
NSLDS.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-002 – NSLDS Reporting (Continued)
1 student out of a sample of 40 students tested did not have their summer 2023 term reported to
the program-level records in the NSLDS.
Cause: Management's procedures to report accurate and timely information to the NSLDS were not
operating effectively.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that
don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR
682.610).
Condition: Certain students’ enrollment information was not reported accurately to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following:
2 students out of a sample of 40 students tested were reported to the NSLDS with the incorrect
enrollment status on both the campus-level and program-level records in the NSLDS.
1 student out of a sample of 40 students had an enrollment effective date in the program-level
records that did not match what was reflected in the University’s records and the campus-level
record in the NSLDS.
8 students out of a sample of 40 students tested were not reported to the campus-level record in
the NSLDS in a timely manner.
2 students out of a sample of 40 students tested did not have their summer 2023 term
enrollment information reported to both the campus-level and program-level records in the
NSLDS.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-002 – NSLDS Reporting (Continued)
1 student out of a sample of 40 students tested did not have their summer 2023 term reported to
the program-level records in the NSLDS.
Cause: Management's procedures to report accurate and timely information to the NSLDS were not
operating effectively.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that
don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR
682.610).
Condition: Certain students’ enrollment information was not reported accurately to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following:
2 students out of a sample of 40 students tested were reported to the NSLDS with the incorrect
enrollment status on both the campus-level and program-level records in the NSLDS.
1 student out of a sample of 40 students had an enrollment effective date in the program-level
records that did not match what was reflected in the University’s records and the campus-level
record in the NSLDS.
8 students out of a sample of 40 students tested were not reported to the campus-level record in
the NSLDS in a timely manner.
2 students out of a sample of 40 students tested did not have their summer 2023 term
enrollment information reported to both the campus-level and program-level records in the
NSLDS.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-002 – NSLDS Reporting (Continued)
1 student out of a sample of 40 students tested did not have their summer 2023 term reported to
the program-level records in the NSLDS.
Cause: Management's procedures to report accurate and timely information to the NSLDS were not
operating effectively.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that
don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR
682.610).
Condition: Certain students’ enrollment information was not reported accurately to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following:
2 students out of a sample of 40 students tested were reported to the NSLDS with the incorrect
enrollment status on both the campus-level and program-level records in the NSLDS.
1 student out of a sample of 40 students had an enrollment effective date in the program-level
records that did not match what was reflected in the University’s records and the campus-level
record in the NSLDS.
8 students out of a sample of 40 students tested were not reported to the campus-level record in
the NSLDS in a timely manner.
2 students out of a sample of 40 students tested did not have their summer 2023 term
enrollment information reported to both the campus-level and program-level records in the
NSLDS.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-002 – NSLDS Reporting (Continued)
1 student out of a sample of 40 students tested did not have their summer 2023 term reported to
the program-level records in the NSLDS.
Cause: Management's procedures to report accurate and timely information to the NSLDS were not
operating effectively.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to
calculate the percentage of the payment period or period of enrollment completed. Institutionally
scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation
as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal
Student Aid earned (34 CFR 668.22(f)(2)(i)).
Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks
were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition,
the University did not use the correct date of withdrawal for the one student.
Questioned costs: $67.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-003 – Return of Title IV (R2T4) Calculations (Continued)
Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students
tested. During the break, the student notified the University they would not return after the scheduled
break and the date of notification was used as the withdrawal date, rather than the last date of
attendance before the scheduled break.
Cause: Management had a process in place for using the correct withdrawal date and number of days
in the schedule break, but the process was not followed for the one student.
Effect: The University did not complete an accurate calculation as defined by Federal regulations.
Repeat Finding: No.
Recommendation: We recommend the University review the R2T4 requirements and implement
procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the
correct date of withdrawal.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to
calculate the percentage of the payment period or period of enrollment completed. Institutionally
scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation
as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal
Student Aid earned (34 CFR 668.22(f)(2)(i)).
Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks
were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition,
the University did not use the correct date of withdrawal for the one student.
Questioned costs: $67.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-003 – Return of Title IV (R2T4) Calculations (Continued)
Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students
tested. During the break, the student notified the University they would not return after the scheduled
break and the date of notification was used as the withdrawal date, rather than the last date of
attendance before the scheduled break.
Cause: Management had a process in place for using the correct withdrawal date and number of days
in the schedule break, but the process was not followed for the one student.
Effect: The University did not complete an accurate calculation as defined by Federal regulations.
Repeat Finding: No.
Recommendation: We recommend the University review the R2T4 requirements and implement
procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the
correct date of withdrawal.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to
calculate the percentage of the payment period or period of enrollment completed. Institutionally
scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation
as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal
Student Aid earned (34 CFR 668.22(f)(2)(i)).
Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks
were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition,
the University did not use the correct date of withdrawal for the one student.
Questioned costs: $67.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-003 – Return of Title IV (R2T4) Calculations (Continued)
Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students
tested. During the break, the student notified the University they would not return after the scheduled
break and the date of notification was used as the withdrawal date, rather than the last date of
attendance before the scheduled break.
Cause: Management had a process in place for using the correct withdrawal date and number of days
in the schedule break, but the process was not followed for the one student.
Effect: The University did not complete an accurate calculation as defined by Federal regulations.
Repeat Finding: No.
Recommendation: We recommend the University review the R2T4 requirements and implement
procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the
correct date of withdrawal.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to
calculate the percentage of the payment period or period of enrollment completed. Institutionally
scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation
as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal
Student Aid earned (34 CFR 668.22(f)(2)(i)).
Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks
were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition,
the University did not use the correct date of withdrawal for the one student.
Questioned costs: $67.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-003 – Return of Title IV (R2T4) Calculations (Continued)
Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students
tested. During the break, the student notified the University they would not return after the scheduled
break and the date of notification was used as the withdrawal date, rather than the last date of
attendance before the scheduled break.
Cause: Management had a process in place for using the correct withdrawal date and number of days
in the schedule break, but the process was not followed for the one student.
Effect: The University did not complete an accurate calculation as defined by Federal regulations.
Repeat Finding: No.
Recommendation: We recommend the University review the R2T4 requirements and implement
procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the
correct date of withdrawal.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to
calculate the percentage of the payment period or period of enrollment completed. Institutionally
scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation
as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal
Student Aid earned (34 CFR 668.22(f)(2)(i)).
Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks
were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition,
the University did not use the correct date of withdrawal for the one student.
Questioned costs: $67.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-003 – Return of Title IV (R2T4) Calculations (Continued)
Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students
tested. During the break, the student notified the University they would not return after the scheduled
break and the date of notification was used as the withdrawal date, rather than the last date of
attendance before the scheduled break.
Cause: Management had a process in place for using the correct withdrawal date and number of days
in the schedule break, but the process was not followed for the one student.
Effect: The University did not complete an accurate calculation as defined by Federal regulations.
Repeat Finding: No.
Recommendation: We recommend the University review the R2T4 requirements and implement
procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the
correct date of withdrawal.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to
calculate the percentage of the payment period or period of enrollment completed. Institutionally
scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation
as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal
Student Aid earned (34 CFR 668.22(f)(2)(i)).
Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks
were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition,
the University did not use the correct date of withdrawal for the one student.
Questioned costs: $67.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-003 – Return of Title IV (R2T4) Calculations (Continued)
Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students
tested. During the break, the student notified the University they would not return after the scheduled
break and the date of notification was used as the withdrawal date, rather than the last date of
attendance before the scheduled break.
Cause: Management had a process in place for using the correct withdrawal date and number of days
in the schedule break, but the process was not followed for the one student.
Effect: The University did not complete an accurate calculation as defined by Federal regulations.
Repeat Finding: No.
Recommendation: We recommend the University review the R2T4 requirements and implement
procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the
correct date of withdrawal.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Department of Education no later than 240 days after the date it issued that
check.
Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial
aid were outstanding more than 240 days.
Questioned Costs: $11,438.
Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which
were not returned to the Department of Education.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-004 – Title IV Refund Checks (Continued)
Cause: The University did not have a process in place to return Title IV refund checks outstanding over
240 days.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat Finding: No.
Auditors’ Recommendation: We recommend the University review its policies and procedures related
to outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Department of Education no later than 240 days after the date it issued that
check.
Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial
aid were outstanding more than 240 days.
Questioned Costs: $11,438.
Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which
were not returned to the Department of Education.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-004 – Title IV Refund Checks (Continued)
Cause: The University did not have a process in place to return Title IV refund checks outstanding over
240 days.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat Finding: No.
Auditors’ Recommendation: We recommend the University review its policies and procedures related
to outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Department of Education no later than 240 days after the date it issued that
check.
Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial
aid were outstanding more than 240 days.
Questioned Costs: $11,438.
Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which
were not returned to the Department of Education.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-004 – Title IV Refund Checks (Continued)
Cause: The University did not have a process in place to return Title IV refund checks outstanding over
240 days.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat Finding: No.
Auditors’ Recommendation: We recommend the University review its policies and procedures related
to outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Department of Education no later than 240 days after the date it issued that
check.
Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial
aid were outstanding more than 240 days.
Questioned Costs: $11,438.
Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which
were not returned to the Department of Education.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-004 – Title IV Refund Checks (Continued)
Cause: The University did not have a process in place to return Title IV refund checks outstanding over
240 days.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat Finding: No.
Auditors’ Recommendation: We recommend the University review its policies and procedures related
to outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Department of Education no later than 240 days after the date it issued that
check.
Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial
aid were outstanding more than 240 days.
Questioned Costs: $11,438.
Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which
were not returned to the Department of Education.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-004 – Title IV Refund Checks (Continued)
Cause: The University did not have a process in place to return Title IV refund checks outstanding over
240 days.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat Finding: No.
Auditors’ Recommendation: We recommend the University review its policies and procedures related
to outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Department of Education no later than 240 days after the date it issued that
check.
Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial
aid were outstanding more than 240 days.
Questioned Costs: $11,438.
Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which
were not returned to the Department of Education.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-004 – Title IV Refund Checks (Continued)
Cause: The University did not have a process in place to return Title IV refund checks outstanding over
240 days.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat Finding: No.
Auditors’ Recommendation: We recommend the University review its policies and procedures related
to outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell
grant for an academic year is based upon the payment and disbursement schedule published by the
Secretary for each award year. The payment schedule takes into account the cost of attendance, the
student’s estimated family contribution (EFC) and the enrollment status of the student.
Condition: 1 of 40 students tested was under awarded and disbursed Pell grant funds.
Questioned costs: $450.
Context: An incorrect EFC was used to calculate the Pell award.
Cause: The student made changes to their Free Application for Federal Student Aid (FASFA) and the
University did not use the most updated version of the student’s FASFA.
Effect: A student was under awarded and disbursed Pell funds.
Repeat Finding: No.
Recommendation: We recommend that the University establish a process to review changes and
updates to a student’s FASFA prior to disbursing funds to ensure the most up to date and accurate
information is being used for Pell awards.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that
don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR
682.610).
Condition: Certain students’ enrollment information was not reported accurately to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following:
2 students out of a sample of 40 students tested were reported to the NSLDS with the incorrect
enrollment status on both the campus-level and program-level records in the NSLDS.
1 student out of a sample of 40 students had an enrollment effective date in the program-level
records that did not match what was reflected in the University’s records and the campus-level
record in the NSLDS.
8 students out of a sample of 40 students tested were not reported to the campus-level record in
the NSLDS in a timely manner.
2 students out of a sample of 40 students tested did not have their summer 2023 term
enrollment information reported to both the campus-level and program-level records in the
NSLDS.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-002 – NSLDS Reporting (Continued)
1 student out of a sample of 40 students tested did not have their summer 2023 term reported to
the program-level records in the NSLDS.
Cause: Management's procedures to report accurate and timely information to the NSLDS were not
operating effectively.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that
don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR
682.610).
Condition: Certain students’ enrollment information was not reported accurately to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following:
2 students out of a sample of 40 students tested were reported to the NSLDS with the incorrect
enrollment status on both the campus-level and program-level records in the NSLDS.
1 student out of a sample of 40 students had an enrollment effective date in the program-level
records that did not match what was reflected in the University’s records and the campus-level
record in the NSLDS.
8 students out of a sample of 40 students tested were not reported to the campus-level record in
the NSLDS in a timely manner.
2 students out of a sample of 40 students tested did not have their summer 2023 term
enrollment information reported to both the campus-level and program-level records in the
NSLDS.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-002 – NSLDS Reporting (Continued)
1 student out of a sample of 40 students tested did not have their summer 2023 term reported to
the program-level records in the NSLDS.
Cause: Management's procedures to report accurate and timely information to the NSLDS were not
operating effectively.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that
don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR
682.610).
Condition: Certain students’ enrollment information was not reported accurately to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following:
2 students out of a sample of 40 students tested were reported to the NSLDS with the incorrect
enrollment status on both the campus-level and program-level records in the NSLDS.
1 student out of a sample of 40 students had an enrollment effective date in the program-level
records that did not match what was reflected in the University’s records and the campus-level
record in the NSLDS.
8 students out of a sample of 40 students tested were not reported to the campus-level record in
the NSLDS in a timely manner.
2 students out of a sample of 40 students tested did not have their summer 2023 term
enrollment information reported to both the campus-level and program-level records in the
NSLDS.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-002 – NSLDS Reporting (Continued)
1 student out of a sample of 40 students tested did not have their summer 2023 term reported to
the program-level records in the NSLDS.
Cause: Management's procedures to report accurate and timely information to the NSLDS were not
operating effectively.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that
don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR
682.610).
Condition: Certain students’ enrollment information was not reported accurately to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following:
2 students out of a sample of 40 students tested were reported to the NSLDS with the incorrect
enrollment status on both the campus-level and program-level records in the NSLDS.
1 student out of a sample of 40 students had an enrollment effective date in the program-level
records that did not match what was reflected in the University’s records and the campus-level
record in the NSLDS.
8 students out of a sample of 40 students tested were not reported to the campus-level record in
the NSLDS in a timely manner.
2 students out of a sample of 40 students tested did not have their summer 2023 term
enrollment information reported to both the campus-level and program-level records in the
NSLDS.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-002 – NSLDS Reporting (Continued)
1 student out of a sample of 40 students tested did not have their summer 2023 term reported to
the program-level records in the NSLDS.
Cause: Management's procedures to report accurate and timely information to the NSLDS were not
operating effectively.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to
calculate the percentage of the payment period or period of enrollment completed. Institutionally
scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation
as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal
Student Aid earned (34 CFR 668.22(f)(2)(i)).
Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks
were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition,
the University did not use the correct date of withdrawal for the one student.
Questioned costs: $67.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-003 – Return of Title IV (R2T4) Calculations (Continued)
Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students
tested. During the break, the student notified the University they would not return after the scheduled
break and the date of notification was used as the withdrawal date, rather than the last date of
attendance before the scheduled break.
Cause: Management had a process in place for using the correct withdrawal date and number of days
in the schedule break, but the process was not followed for the one student.
Effect: The University did not complete an accurate calculation as defined by Federal regulations.
Repeat Finding: No.
Recommendation: We recommend the University review the R2T4 requirements and implement
procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the
correct date of withdrawal.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to
calculate the percentage of the payment period or period of enrollment completed. Institutionally
scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation
as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal
Student Aid earned (34 CFR 668.22(f)(2)(i)).
Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks
were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition,
the University did not use the correct date of withdrawal for the one student.
Questioned costs: $67.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-003 – Return of Title IV (R2T4) Calculations (Continued)
Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students
tested. During the break, the student notified the University they would not return after the scheduled
break and the date of notification was used as the withdrawal date, rather than the last date of
attendance before the scheduled break.
Cause: Management had a process in place for using the correct withdrawal date and number of days
in the schedule break, but the process was not followed for the one student.
Effect: The University did not complete an accurate calculation as defined by Federal regulations.
Repeat Finding: No.
Recommendation: We recommend the University review the R2T4 requirements and implement
procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the
correct date of withdrawal.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to
calculate the percentage of the payment period or period of enrollment completed. Institutionally
scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation
as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal
Student Aid earned (34 CFR 668.22(f)(2)(i)).
Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks
were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition,
the University did not use the correct date of withdrawal for the one student.
Questioned costs: $67.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-003 – Return of Title IV (R2T4) Calculations (Continued)
Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students
tested. During the break, the student notified the University they would not return after the scheduled
break and the date of notification was used as the withdrawal date, rather than the last date of
attendance before the scheduled break.
Cause: Management had a process in place for using the correct withdrawal date and number of days
in the schedule break, but the process was not followed for the one student.
Effect: The University did not complete an accurate calculation as defined by Federal regulations.
Repeat Finding: No.
Recommendation: We recommend the University review the R2T4 requirements and implement
procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the
correct date of withdrawal.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to
calculate the percentage of the payment period or period of enrollment completed. Institutionally
scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation
as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal
Student Aid earned (34 CFR 668.22(f)(2)(i)).
Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks
were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition,
the University did not use the correct date of withdrawal for the one student.
Questioned costs: $67.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-003 – Return of Title IV (R2T4) Calculations (Continued)
Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students
tested. During the break, the student notified the University they would not return after the scheduled
break and the date of notification was used as the withdrawal date, rather than the last date of
attendance before the scheduled break.
Cause: Management had a process in place for using the correct withdrawal date and number of days
in the schedule break, but the process was not followed for the one student.
Effect: The University did not complete an accurate calculation as defined by Federal regulations.
Repeat Finding: No.
Recommendation: We recommend the University review the R2T4 requirements and implement
procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the
correct date of withdrawal.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to
calculate the percentage of the payment period or period of enrollment completed. Institutionally
scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation
as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal
Student Aid earned (34 CFR 668.22(f)(2)(i)).
Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks
were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition,
the University did not use the correct date of withdrawal for the one student.
Questioned costs: $67.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-003 – Return of Title IV (R2T4) Calculations (Continued)
Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students
tested. During the break, the student notified the University they would not return after the scheduled
break and the date of notification was used as the withdrawal date, rather than the last date of
attendance before the scheduled break.
Cause: Management had a process in place for using the correct withdrawal date and number of days
in the schedule break, but the process was not followed for the one student.
Effect: The University did not complete an accurate calculation as defined by Federal regulations.
Repeat Finding: No.
Recommendation: We recommend the University review the R2T4 requirements and implement
procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the
correct date of withdrawal.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Once a students’ withdrawal date is determined, a school needs to
calculate the percentage of the payment period or period of enrollment completed. Institutionally
scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation
as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal
Student Aid earned (34 CFR 668.22(f)(2)(i)).
Condition: During our testing, it was noted the University’s process did not ensure scheduled breaks
were properly factored into an R2T4 calculation for one student in the Spring 2023 term. In addition,
the University did not use the correct date of withdrawal for the one student.
Questioned costs: $67.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-003 – Return of Title IV (R2T4) Calculations (Continued)
Context: We noted the University did not correctly factor in scheduled breaks to 1 of the 8 students
tested. During the break, the student notified the University they would not return after the scheduled
break and the date of notification was used as the withdrawal date, rather than the last date of
attendance before the scheduled break.
Cause: Management had a process in place for using the correct withdrawal date and number of days
in the schedule break, but the process was not followed for the one student.
Effect: The University did not complete an accurate calculation as defined by Federal regulations.
Repeat Finding: No.
Recommendation: We recommend the University review the R2T4 requirements and implement
procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the
correct date of withdrawal.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Department of Education no later than 240 days after the date it issued that
check.
Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial
aid were outstanding more than 240 days.
Questioned Costs: $11,438.
Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which
were not returned to the Department of Education.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-004 – Title IV Refund Checks (Continued)
Cause: The University did not have a process in place to return Title IV refund checks outstanding over
240 days.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat Finding: No.
Auditors’ Recommendation: We recommend the University review its policies and procedures related
to outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Department of Education no later than 240 days after the date it issued that
check.
Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial
aid were outstanding more than 240 days.
Questioned Costs: $11,438.
Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which
were not returned to the Department of Education.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-004 – Title IV Refund Checks (Continued)
Cause: The University did not have a process in place to return Title IV refund checks outstanding over
240 days.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat Finding: No.
Auditors’ Recommendation: We recommend the University review its policies and procedures related
to outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Department of Education no later than 240 days after the date it issued that
check.
Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial
aid were outstanding more than 240 days.
Questioned Costs: $11,438.
Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which
were not returned to the Department of Education.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-004 – Title IV Refund Checks (Continued)
Cause: The University did not have a process in place to return Title IV refund checks outstanding over
240 days.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat Finding: No.
Auditors’ Recommendation: We recommend the University review its policies and procedures related
to outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Department of Education no later than 240 days after the date it issued that
check.
Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial
aid were outstanding more than 240 days.
Questioned Costs: $11,438.
Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which
were not returned to the Department of Education.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-004 – Title IV Refund Checks (Continued)
Cause: The University did not have a process in place to return Title IV refund checks outstanding over
240 days.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat Finding: No.
Auditors’ Recommendation: We recommend the University review its policies and procedures related
to outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Department of Education no later than 240 days after the date it issued that
check.
Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial
aid were outstanding more than 240 days.
Questioned Costs: $11,438.
Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which
were not returned to the Department of Education.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-004 – Title IV Refund Checks (Continued)
Cause: The University did not have a process in place to return Title IV refund checks outstanding over
240 days.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat Finding: No.
Auditors’ Recommendation: We recommend the University review its policies and procedures related
to outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Department of Education no later than 240 days after the date it issued that
check.
Condition: During our testing of refund checks, we noted student refunds of Title IV federal financial
aid were outstanding more than 240 days.
Questioned Costs: $11,438.
Context: During our testing, we noted 16 out of 16 refund checks outstanding over 240 days which
were not returned to the Department of Education.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-004 – Title IV Refund Checks (Continued)
Cause: The University did not have a process in place to return Title IV refund checks outstanding over
240 days.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Repeat Finding: No.
Auditors’ Recommendation: We recommend the University review its policies and procedures related
to outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials: There is no disagreement with the finding.