Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – Loan Disbursement Notification Testing When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR section 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan, FPL funds, or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than 7 days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan.
Condition: The University failed to provide loan disbursement notifications for all applicable students during the year.
Cause: Insufficient administrative oversight with respect to loan disbursement notifications.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide loan disbursement notifications.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends loan disbursement notifications within the required timeframe.
Views of Responsible Officials
and Planned Corrective Actions:
The University will change the process from manually pulling loan disbursement lists from the Ellucian Colleague system using the TFAR report to setting up Communications Management within the Colleague system so that the notifications are automatically emailed, and no manual intervention is needed.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – General Disbursement Testing Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)).
Condition: The University failed to provide award letters to all applicable students prior to disbursing funds.
Cause: Insufficient administrative oversight with respect to award letters.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide award letters prior to disbursing funds.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends award letters prior to disbursing funds.
Views of Responsible Officials
and Planned Corrective Actions:
Campus Logic is used to send financial aid award letters to full-time undergraduate students. Part-time and graduate students fill out an institutional application, upon which their financial aid is based. These students have typically been sent an email directing them to view their aid on the Self-Service portal when their application has been reviewed. Through Self-Service, students have the ability to accept or decline their loans. Starting with the 2024-2025 school year, an award letter will be sent from Campus Logic to this population as well. They will no longer be sent an email directing them to Self-Service.
Federal Program: Student Financial Assistance Cluster (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Federal Work Study An institution may not compensate a student employed under the Federal Work Study (“FWS”) program until the student earns that compensation. (34 CFR 675.16(a)(5))
Condition: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Cause: Insufficient administrative oversight with respect to FWS compensation.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University appropriately reflects FWS hours.
Views of Responsible Officials
and Planned Corrective Actions:
Students are awarded Federal Work Study based on financial need and their indication on the FAFSA that they are interested in Federal Work Study. Sometimes, students indicate they are not interested in Federal Work Study but end up pursuing campus employment. In these cases, we have re-allocated some students’ earnings to Federal Work Study if they remained eligible. Beginning with the 2024-2025 school year, all eligible students will be awarded Federal Work Study, regardless of their expressed interest. This will minimize the need to re-allocate funding between campus employment and Federal Work Study funding sources. Additionally, the Payroll department will enhance scrutiny and review within the federal work-study payroll process to ensure timely receipt of supporting documents for re-allocation and rectification of any errors before payroll processing.
Federal Program: Student Financial Assistance Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Enrollment Reporting - The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 60 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: The University did not submit an accurate status change notification to the NSLDS website for a certain student who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year.
Cause: Insufficient administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: For 1 of 25 students sampled whose status changed during the fiscal year, the University failed to report an accurate enrollment status.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-002 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions:
A student completed a Certificate through the University and was not reported to NSLDS as having graduated. Further investigation found that the student was included in our list students who finished programs of study that led to certification through the Pennsylvania Department of Education. These students do not complete credentials at the University and do not earn certificates from the University. The University will make sure that all students who earn a “G” status of graduated are reported correctly to National Student Clearinghouse, and then to NSLDS. This will include all students who are in certificate programs that earn a credential and are graduated.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – Loan Disbursement Notification Testing When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR section 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan, FPL funds, or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than 7 days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan.
Condition: The University failed to provide loan disbursement notifications for all applicable students during the year.
Cause: Insufficient administrative oversight with respect to loan disbursement notifications.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide loan disbursement notifications.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends loan disbursement notifications within the required timeframe.
Views of Responsible Officials
and Planned Corrective Actions:
The University will change the process from manually pulling loan disbursement lists from the Ellucian Colleague system using the TFAR report to setting up Communications Management within the Colleague system so that the notifications are automatically emailed, and no manual intervention is needed.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – General Disbursement Testing Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)).
Condition: The University failed to provide award letters to all applicable students prior to disbursing funds.
Cause: Insufficient administrative oversight with respect to award letters.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide award letters prior to disbursing funds.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends award letters prior to disbursing funds.
Views of Responsible Officials
and Planned Corrective Actions:
Campus Logic is used to send financial aid award letters to full-time undergraduate students. Part-time and graduate students fill out an institutional application, upon which their financial aid is based. These students have typically been sent an email directing them to view their aid on the Self-Service portal when their application has been reviewed. Through Self-Service, students have the ability to accept or decline their loans. Starting with the 2024-2025 school year, an award letter will be sent from Campus Logic to this population as well. They will no longer be sent an email directing them to Self-Service.
Federal Program: Student Financial Assistance Cluster (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Federal Work Study An institution may not compensate a student employed under the Federal Work Study (“FWS”) program until the student earns that compensation. (34 CFR 675.16(a)(5))
Condition: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Cause: Insufficient administrative oversight with respect to FWS compensation.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University appropriately reflects FWS hours.
Views of Responsible Officials
and Planned Corrective Actions:
Students are awarded Federal Work Study based on financial need and their indication on the FAFSA that they are interested in Federal Work Study. Sometimes, students indicate they are not interested in Federal Work Study but end up pursuing campus employment. In these cases, we have re-allocated some students’ earnings to Federal Work Study if they remained eligible. Beginning with the 2024-2025 school year, all eligible students will be awarded Federal Work Study, regardless of their expressed interest. This will minimize the need to re-allocate funding between campus employment and Federal Work Study funding sources. Additionally, the Payroll department will enhance scrutiny and review within the federal work-study payroll process to ensure timely receipt of supporting documents for re-allocation and rectification of any errors before payroll processing.
Federal Program: Student Financial Assistance Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Enrollment Reporting - The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 60 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: The University did not submit an accurate status change notification to the NSLDS website for a certain student who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year.
Cause: Insufficient administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: For 1 of 25 students sampled whose status changed during the fiscal year, the University failed to report an accurate enrollment status.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-002 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions:
A student completed a Certificate through the University and was not reported to NSLDS as having graduated. Further investigation found that the student was included in our list students who finished programs of study that led to certification through the Pennsylvania Department of Education. These students do not complete credentials at the University and do not earn certificates from the University. The University will make sure that all students who earn a “G” status of graduated are reported correctly to National Student Clearinghouse, and then to NSLDS. This will include all students who are in certificate programs that earn a credential and are graduated.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – Loan Disbursement Notification Testing When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR section 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan, FPL funds, or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than 7 days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan.
Condition: The University failed to provide loan disbursement notifications for all applicable students during the year.
Cause: Insufficient administrative oversight with respect to loan disbursement notifications.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide loan disbursement notifications.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends loan disbursement notifications within the required timeframe.
Views of Responsible Officials
and Planned Corrective Actions:
The University will change the process from manually pulling loan disbursement lists from the Ellucian Colleague system using the TFAR report to setting up Communications Management within the Colleague system so that the notifications are automatically emailed, and no manual intervention is needed.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – General Disbursement Testing Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)).
Condition: The University failed to provide award letters to all applicable students prior to disbursing funds.
Cause: Insufficient administrative oversight with respect to award letters.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide award letters prior to disbursing funds.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends award letters prior to disbursing funds.
Views of Responsible Officials
and Planned Corrective Actions:
Campus Logic is used to send financial aid award letters to full-time undergraduate students. Part-time and graduate students fill out an institutional application, upon which their financial aid is based. These students have typically been sent an email directing them to view their aid on the Self-Service portal when their application has been reviewed. Through Self-Service, students have the ability to accept or decline their loans. Starting with the 2024-2025 school year, an award letter will be sent from Campus Logic to this population as well. They will no longer be sent an email directing them to Self-Service.
Federal Program: Student Financial Assistance Cluster (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Federal Work Study An institution may not compensate a student employed under the Federal Work Study (“FWS”) program until the student earns that compensation. (34 CFR 675.16(a)(5))
Condition: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Cause: Insufficient administrative oversight with respect to FWS compensation.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University appropriately reflects FWS hours.
Views of Responsible Officials
and Planned Corrective Actions:
Students are awarded Federal Work Study based on financial need and their indication on the FAFSA that they are interested in Federal Work Study. Sometimes, students indicate they are not interested in Federal Work Study but end up pursuing campus employment. In these cases, we have re-allocated some students’ earnings to Federal Work Study if they remained eligible. Beginning with the 2024-2025 school year, all eligible students will be awarded Federal Work Study, regardless of their expressed interest. This will minimize the need to re-allocate funding between campus employment and Federal Work Study funding sources. Additionally, the Payroll department will enhance scrutiny and review within the federal work-study payroll process to ensure timely receipt of supporting documents for re-allocation and rectification of any errors before payroll processing.
Federal Program: Student Financial Assistance Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Enrollment Reporting - The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 60 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: The University did not submit an accurate status change notification to the NSLDS website for a certain student who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year.
Cause: Insufficient administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: For 1 of 25 students sampled whose status changed during the fiscal year, the University failed to report an accurate enrollment status.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-002 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions:
A student completed a Certificate through the University and was not reported to NSLDS as having graduated. Further investigation found that the student was included in our list students who finished programs of study that led to certification through the Pennsylvania Department of Education. These students do not complete credentials at the University and do not earn certificates from the University. The University will make sure that all students who earn a “G” status of graduated are reported correctly to National Student Clearinghouse, and then to NSLDS. This will include all students who are in certificate programs that earn a credential and are graduated.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – Loan Disbursement Notification Testing When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR section 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan, FPL funds, or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than 7 days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan.
Condition: The University failed to provide loan disbursement notifications for all applicable students during the year.
Cause: Insufficient administrative oversight with respect to loan disbursement notifications.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide loan disbursement notifications.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends loan disbursement notifications within the required timeframe.
Views of Responsible Officials
and Planned Corrective Actions:
The University will change the process from manually pulling loan disbursement lists from the Ellucian Colleague system using the TFAR report to setting up Communications Management within the Colleague system so that the notifications are automatically emailed, and no manual intervention is needed.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – General Disbursement Testing Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)).
Condition: The University failed to provide award letters to all applicable students prior to disbursing funds.
Cause: Insufficient administrative oversight with respect to award letters.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide award letters prior to disbursing funds.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends award letters prior to disbursing funds.
Views of Responsible Officials
and Planned Corrective Actions:
Campus Logic is used to send financial aid award letters to full-time undergraduate students. Part-time and graduate students fill out an institutional application, upon which their financial aid is based. These students have typically been sent an email directing them to view their aid on the Self-Service portal when their application has been reviewed. Through Self-Service, students have the ability to accept or decline their loans. Starting with the 2024-2025 school year, an award letter will be sent from Campus Logic to this population as well. They will no longer be sent an email directing them to Self-Service.
Federal Program: Student Financial Assistance Cluster (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Federal Work Study An institution may not compensate a student employed under the Federal Work Study (“FWS”) program until the student earns that compensation. (34 CFR 675.16(a)(5))
Condition: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Cause: Insufficient administrative oversight with respect to FWS compensation.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University appropriately reflects FWS hours.
Views of Responsible Officials
and Planned Corrective Actions:
Students are awarded Federal Work Study based on financial need and their indication on the FAFSA that they are interested in Federal Work Study. Sometimes, students indicate they are not interested in Federal Work Study but end up pursuing campus employment. In these cases, we have re-allocated some students’ earnings to Federal Work Study if they remained eligible. Beginning with the 2024-2025 school year, all eligible students will be awarded Federal Work Study, regardless of their expressed interest. This will minimize the need to re-allocate funding between campus employment and Federal Work Study funding sources. Additionally, the Payroll department will enhance scrutiny and review within the federal work-study payroll process to ensure timely receipt of supporting documents for re-allocation and rectification of any errors before payroll processing.
Federal Program: Student Financial Assistance Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Enrollment Reporting - The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 60 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: The University did not submit an accurate status change notification to the NSLDS website for a certain student who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year.
Cause: Insufficient administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: For 1 of 25 students sampled whose status changed during the fiscal year, the University failed to report an accurate enrollment status.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-002 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions:
A student completed a Certificate through the University and was not reported to NSLDS as having graduated. Further investigation found that the student was included in our list students who finished programs of study that led to certification through the Pennsylvania Department of Education. These students do not complete credentials at the University and do not earn certificates from the University. The University will make sure that all students who earn a “G” status of graduated are reported correctly to National Student Clearinghouse, and then to NSLDS. This will include all students who are in certificate programs that earn a credential and are graduated.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – Loan Disbursement Notification Testing When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR section 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan, FPL funds, or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than 7 days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan.
Condition: The University failed to provide loan disbursement notifications for all applicable students during the year.
Cause: Insufficient administrative oversight with respect to loan disbursement notifications.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide loan disbursement notifications.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends loan disbursement notifications within the required timeframe.
Views of Responsible Officials
and Planned Corrective Actions:
The University will change the process from manually pulling loan disbursement lists from the Ellucian Colleague system using the TFAR report to setting up Communications Management within the Colleague system so that the notifications are automatically emailed, and no manual intervention is needed.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – General Disbursement Testing Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)).
Condition: The University failed to provide award letters to all applicable students prior to disbursing funds.
Cause: Insufficient administrative oversight with respect to award letters.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide award letters prior to disbursing funds.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends award letters prior to disbursing funds.
Views of Responsible Officials
and Planned Corrective Actions:
Campus Logic is used to send financial aid award letters to full-time undergraduate students. Part-time and graduate students fill out an institutional application, upon which their financial aid is based. These students have typically been sent an email directing them to view their aid on the Self-Service portal when their application has been reviewed. Through Self-Service, students have the ability to accept or decline their loans. Starting with the 2024-2025 school year, an award letter will be sent from Campus Logic to this population as well. They will no longer be sent an email directing them to Self-Service.
Federal Program: Student Financial Assistance Cluster (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Federal Work Study An institution may not compensate a student employed under the Federal Work Study (“FWS”) program until the student earns that compensation. (34 CFR 675.16(a)(5))
Condition: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Cause: Insufficient administrative oversight with respect to FWS compensation.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University appropriately reflects FWS hours.
Views of Responsible Officials
and Planned Corrective Actions:
Students are awarded Federal Work Study based on financial need and their indication on the FAFSA that they are interested in Federal Work Study. Sometimes, students indicate they are not interested in Federal Work Study but end up pursuing campus employment. In these cases, we have re-allocated some students’ earnings to Federal Work Study if they remained eligible. Beginning with the 2024-2025 school year, all eligible students will be awarded Federal Work Study, regardless of their expressed interest. This will minimize the need to re-allocate funding between campus employment and Federal Work Study funding sources. Additionally, the Payroll department will enhance scrutiny and review within the federal work-study payroll process to ensure timely receipt of supporting documents for re-allocation and rectification of any errors before payroll processing.
Federal Program: Student Financial Assistance Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Enrollment Reporting - The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 60 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: The University did not submit an accurate status change notification to the NSLDS website for a certain student who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year.
Cause: Insufficient administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: For 1 of 25 students sampled whose status changed during the fiscal year, the University failed to report an accurate enrollment status.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-002 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions:
A student completed a Certificate through the University and was not reported to NSLDS as having graduated. Further investigation found that the student was included in our list students who finished programs of study that led to certification through the Pennsylvania Department of Education. These students do not complete credentials at the University and do not earn certificates from the University. The University will make sure that all students who earn a “G” status of graduated are reported correctly to National Student Clearinghouse, and then to NSLDS. This will include all students who are in certificate programs that earn a credential and are graduated.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – Loan Disbursement Notification Testing When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR section 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan, FPL funds, or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than 7 days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan.
Condition: The University failed to provide loan disbursement notifications for all applicable students during the year.
Cause: Insufficient administrative oversight with respect to loan disbursement notifications.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide loan disbursement notifications.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends loan disbursement notifications within the required timeframe.
Views of Responsible Officials
and Planned Corrective Actions:
The University will change the process from manually pulling loan disbursement lists from the Ellucian Colleague system using the TFAR report to setting up Communications Management within the Colleague system so that the notifications are automatically emailed, and no manual intervention is needed.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – General Disbursement Testing Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)).
Condition: The University failed to provide award letters to all applicable students prior to disbursing funds.
Cause: Insufficient administrative oversight with respect to award letters.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide award letters prior to disbursing funds.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends award letters prior to disbursing funds.
Views of Responsible Officials
and Planned Corrective Actions:
Campus Logic is used to send financial aid award letters to full-time undergraduate students. Part-time and graduate students fill out an institutional application, upon which their financial aid is based. These students have typically been sent an email directing them to view their aid on the Self-Service portal when their application has been reviewed. Through Self-Service, students have the ability to accept or decline their loans. Starting with the 2024-2025 school year, an award letter will be sent from Campus Logic to this population as well. They will no longer be sent an email directing them to Self-Service.
Federal Program: Student Financial Assistance Cluster (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Federal Work Study An institution may not compensate a student employed under the Federal Work Study (“FWS”) program until the student earns that compensation. (34 CFR 675.16(a)(5))
Condition: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Cause: Insufficient administrative oversight with respect to FWS compensation.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University appropriately reflects FWS hours.
Views of Responsible Officials
and Planned Corrective Actions:
Students are awarded Federal Work Study based on financial need and their indication on the FAFSA that they are interested in Federal Work Study. Sometimes, students indicate they are not interested in Federal Work Study but end up pursuing campus employment. In these cases, we have re-allocated some students’ earnings to Federal Work Study if they remained eligible. Beginning with the 2024-2025 school year, all eligible students will be awarded Federal Work Study, regardless of their expressed interest. This will minimize the need to re-allocate funding between campus employment and Federal Work Study funding sources. Additionally, the Payroll department will enhance scrutiny and review within the federal work-study payroll process to ensure timely receipt of supporting documents for re-allocation and rectification of any errors before payroll processing.
Federal Program: Student Financial Assistance Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Enrollment Reporting - The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 60 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: The University did not submit an accurate status change notification to the NSLDS website for a certain student who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year.
Cause: Insufficient administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: For 1 of 25 students sampled whose status changed during the fiscal year, the University failed to report an accurate enrollment status.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-002 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions:
A student completed a Certificate through the University and was not reported to NSLDS as having graduated. Further investigation found that the student was included in our list students who finished programs of study that led to certification through the Pennsylvania Department of Education. These students do not complete credentials at the University and do not earn certificates from the University. The University will make sure that all students who earn a “G” status of graduated are reported correctly to National Student Clearinghouse, and then to NSLDS. This will include all students who are in certificate programs that earn a credential and are graduated.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – Loan Disbursement Notification Testing When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR section 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan, FPL funds, or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than 7 days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan.
Condition: The University failed to provide loan disbursement notifications for all applicable students during the year.
Cause: Insufficient administrative oversight with respect to loan disbursement notifications.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide loan disbursement notifications.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends loan disbursement notifications within the required timeframe.
Views of Responsible Officials
and Planned Corrective Actions:
The University will change the process from manually pulling loan disbursement lists from the Ellucian Colleague system using the TFAR report to setting up Communications Management within the Colleague system so that the notifications are automatically emailed, and no manual intervention is needed.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – General Disbursement Testing Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)).
Condition: The University failed to provide award letters to all applicable students prior to disbursing funds.
Cause: Insufficient administrative oversight with respect to award letters.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide award letters prior to disbursing funds.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends award letters prior to disbursing funds.
Views of Responsible Officials
and Planned Corrective Actions:
Campus Logic is used to send financial aid award letters to full-time undergraduate students. Part-time and graduate students fill out an institutional application, upon which their financial aid is based. These students have typically been sent an email directing them to view their aid on the Self-Service portal when their application has been reviewed. Through Self-Service, students have the ability to accept or decline their loans. Starting with the 2024-2025 school year, an award letter will be sent from Campus Logic to this population as well. They will no longer be sent an email directing them to Self-Service.
Federal Program: Student Financial Assistance Cluster (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Federal Work Study An institution may not compensate a student employed under the Federal Work Study (“FWS”) program until the student earns that compensation. (34 CFR 675.16(a)(5))
Condition: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Cause: Insufficient administrative oversight with respect to FWS compensation.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University appropriately reflects FWS hours.
Views of Responsible Officials
and Planned Corrective Actions:
Students are awarded Federal Work Study based on financial need and their indication on the FAFSA that they are interested in Federal Work Study. Sometimes, students indicate they are not interested in Federal Work Study but end up pursuing campus employment. In these cases, we have re-allocated some students’ earnings to Federal Work Study if they remained eligible. Beginning with the 2024-2025 school year, all eligible students will be awarded Federal Work Study, regardless of their expressed interest. This will minimize the need to re-allocate funding between campus employment and Federal Work Study funding sources. Additionally, the Payroll department will enhance scrutiny and review within the federal work-study payroll process to ensure timely receipt of supporting documents for re-allocation and rectification of any errors before payroll processing.
Federal Program: Student Financial Assistance Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Enrollment Reporting - The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 60 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: The University did not submit an accurate status change notification to the NSLDS website for a certain student who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year.
Cause: Insufficient administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: For 1 of 25 students sampled whose status changed during the fiscal year, the University failed to report an accurate enrollment status.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-002 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions:
A student completed a Certificate through the University and was not reported to NSLDS as having graduated. Further investigation found that the student was included in our list students who finished programs of study that led to certification through the Pennsylvania Department of Education. These students do not complete credentials at the University and do not earn certificates from the University. The University will make sure that all students who earn a “G” status of graduated are reported correctly to National Student Clearinghouse, and then to NSLDS. This will include all students who are in certificate programs that earn a credential and are graduated.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – Loan Disbursement Notification Testing When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR section 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan, FPL funds, or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than 7 days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan.
Condition: The University failed to provide loan disbursement notifications for all applicable students during the year.
Cause: Insufficient administrative oversight with respect to loan disbursement notifications.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide loan disbursement notifications.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends loan disbursement notifications within the required timeframe.
Views of Responsible Officials
and Planned Corrective Actions:
The University will change the process from manually pulling loan disbursement lists from the Ellucian Colleague system using the TFAR report to setting up Communications Management within the Colleague system so that the notifications are automatically emailed, and no manual intervention is needed.
Federal Program: Student Financial Assistance Cluster (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions –Disbursements To or On Behalf of Students – General Disbursement Testing Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)).
Condition: The University failed to provide award letters to all applicable students prior to disbursing funds.
Cause: Insufficient administrative oversight with respect to award letters.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 2 out of 40 disbursements, the University failed to provide award letters prior to disbursing funds.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University sends award letters prior to disbursing funds.
Views of Responsible Officials
and Planned Corrective Actions:
Campus Logic is used to send financial aid award letters to full-time undergraduate students. Part-time and graduate students fill out an institutional application, upon which their financial aid is based. These students have typically been sent an email directing them to view their aid on the Self-Service portal when their application has been reviewed. Through Self-Service, students have the ability to accept or decline their loans. Starting with the 2024-2025 school year, an award letter will be sent from Campus Logic to this population as well. They will no longer be sent an email directing them to Self-Service.
Federal Program: Student Financial Assistance Cluster (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Federal Work Study An institution may not compensate a student employed under the Federal Work Study (“FWS”) program until the student earns that compensation. (34 CFR 675.16(a)(5))
Condition: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Cause: Insufficient administrative oversight with respect to FWS compensation.
Effect: The University is not in compliance with federal regulations over disbursing federal funds.
Questioned Costs: None.
Context: For 1 out of 25 disbursements, the documentation supporting the selected student’s FWS pay was incorrect due to a manual error in reflecting the appropriate number of FWS hours. There was no questioned cost associated with this error, as the student was paid for the actual amount of FWS hours worked.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University implement policies to ensure the University appropriately reflects FWS hours.
Views of Responsible Officials
and Planned Corrective Actions:
Students are awarded Federal Work Study based on financial need and their indication on the FAFSA that they are interested in Federal Work Study. Sometimes, students indicate they are not interested in Federal Work Study but end up pursuing campus employment. In these cases, we have re-allocated some students’ earnings to Federal Work Study if they remained eligible. Beginning with the 2024-2025 school year, all eligible students will be awarded Federal Work Study, regardless of their expressed interest. This will minimize the need to re-allocate funding between campus employment and Federal Work Study funding sources. Additionally, the Payroll department will enhance scrutiny and review within the federal work-study payroll process to ensure timely receipt of supporting documents for re-allocation and rectification of any errors before payroll processing.
Federal Program: Student Financial Assistance Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Enrollment Reporting - The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 60 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: The University did not submit an accurate status change notification to the NSLDS website for a certain student who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year.
Cause: Insufficient administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: For 1 of 25 students sampled whose status changed during the fiscal year, the University failed to report an accurate enrollment status.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-002 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions:
A student completed a Certificate through the University and was not reported to NSLDS as having graduated. Further investigation found that the student was included in our list students who finished programs of study that led to certification through the Pennsylvania Department of Education. These students do not complete credentials at the University and do not earn certificates from the University. The University will make sure that all students who earn a “G” status of graduated are reported correctly to National Student Clearinghouse, and then to NSLDS. This will include all students who are in certificate programs that earn a credential and are graduated.