Federal Program: Student Financial Assistance Cluster, Federal Direct Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 U.S. Code of Federal Regulations (CFR) 668.16) requires recipients of Federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition: There was not an adequate system of controls in place that would have prevented or detected potential material noncompliance matters within the Activities Allowed or Unallowed, Eligibility and Special Tests and Provisions (related to Return of Title IV Funds, Enrollment Reporting and Federal Direct Loan Disbursements) compliance requirement areas. Cause: The Organization filled its vacant director of financial aid position in the spring of 2021. It was later discovered that this person did not have the suitable skills required to effectively administer the federal financial aid programs of the Organization and this person was terminated in spring of 2022. Thus, a critical position was left vacant for part of the testing year. Effect: The potential exists that noncompliance could occur in the Activities Allowed or Unallowed, Eligibility and Special Tests and Provisions compliance areas and not be detected by the by the Organization's internal controls over compliance. Questioned Costs: There were no questioned costs associated with this finding. Context: The key position of financial aid director was vacant for part of the testing period. As of the time of our testing, this position has been filled. Recommendation: The Organization should implement procedures to ensure any individuals responsible for the oversight or review of any vendors or individuals administering financial aid are properly trained and knowledgeable of the specific requirements of Title IV. Views of Responsible Official(s): Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements. They have hired a new Director of Financial Aid and Student Housing.
Federal Program: Student Financial Assistance Cluster, Federal Direct Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations stipulate institutions are responsible for timely reporting. Under the Federal Direct Loan programs, institutions must complete and return within 15 days the enrollment reporting roster file placed in the Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by the Department of Education via the National Student Loan Data System (NSLDS). Condition: One roster file out of three tested were not completed and returned within the 15-day requirement to the NSLDS. This sample was not statistically valid. Cause: The Organization's procedures for complying with this requirement were not designed appropriately to allow for timely return of the file. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: There were no questioned costs associated with this finding. Context: The key position of financial aid director was vacant for part of the testing period. This position is responsible for reporting of the roster files. As of the time of our testing, this position has been filled. Recommendation: The Organization should revise its procedures to ensure timely completion and return of the enrollment reporting roster files. Views of Responsible Official(s): Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements. They have hired a new Director of Financial Aid and Student Housing.
Federal Program: Student Financial Assistance Cluster, Federal Direct Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations stipulate institutions must report to the National Student Loan Data System (NSLDS) when a student to whom a loan made under Title IV ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended within 30 days after the institution discovers the student's status changed, unless the institution expects to submit its next updated enrollment report within 60 days. (34 CFR 385.309(b)). Condition: For six students out of nine tested, the change in student status was not reported to the NSLDS within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. This sample was not statistically valid. Cause: The Organization's procedures for complying with this requirement were not designed appropriately to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: There were no questioned costs associated with this finding. Context: The key position of financial aid director was vacant for part of the testing period. This position is responsible for proper enrollment reporting. As of the time of our testing, this position has been filled. Recommendation: The Organization should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe. Views of Responsible Official(s): Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements. They have hired a new Director of Financial Aid and Student Housing.
Federal Program: Student Financial Assistance Cluster, Federal Direct Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations stipulate institutions must reconcile their Federal Direct Loan School Account Statements (SAS) to the institution's records each month. Condition: The Organization did not reconcile its SAS data file to its financial records for all 12 months of the fiscal year; however, the Organization did complete the annual reconciliation at the end of the fiscal year. Cause: Lack of competency and turnover in the financial aid office contributed to the Organization not being able to perform the reconciliations in the required timeframe. Effect: The potential exists that an error could occur in the financial records and not be detected and corrected within a timely manner by employees in the normal course of performing their assigned functions. Questioned Costs: There were no questioned costs associated with this finding. Context: The key position of financial aid director was vacant for part of the testing period. This position is responsible for proper enrollment reporting. As of the time of our testing, this position has been filled. Recommendation: The Organization should implement policy and procedures to ensure that the monthly SAS reconciliations are performed on a timely basis and correct all errors to adhere to federal regulations. Views of Responsible Official(s): Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements. The Organization has hired a new Director of Financial Aid and Student Housing who started July 1, 2022, who is committed to completing the reconciliations in a timely manner. Furthermore, a different individual will check and determine that the reconciliations are completed timely.
Federal Program: Student Financial Assistance Cluster, Federal Direct Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations require institutions to refund any unearned portions of grants and loans to the Title IV program within 45 days after a student withdraws Condition: Federal aid refunds were not calculated correctly for one student out of three tested and resulted in the Organization not refunding correct amounts. This was not a statistically valid sample. Cause: The Organization did not perform return of Title IV refund calculations during the year. Effect: The Organization did not refund $4,547 of Federal Direct Loans that was not earned for the student. Questioned Costs: Questioned costs of $4,547 were noted during testing. The full population of withdraws was tested. Context: Error was noted for one student out of three selected for testing. There was a total population of three students who withdrew during the fiscal year under audit that received Title IV aid. The sample was not statistically valid. Recommendation: The Organization should immediately perform a return of Title IV calculation for the student and remit a refund to the Title IV program. The Organization's personnel should implement a procedure to ensure a return of Title IV refund calculation for all students who withdraw on or before a defined point in any semester. This point should be after the 60.0 percent completion mark for fully earning Title IV funds, to ensure that these calculations capture any Title IV funds that need to be refunded. Views of Responsible Official(s): Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements. The Organization has hired a new Director of Financial Aid and Student Housing who started July 1, 2022. This individual will verify the calculation and return the funds to the Title IV program. A different individual who is knowledgeable about withdrawals will monitor to ensure any required refund is made.
Federal Program: Student Financial Assistance Cluster, Federal Direct Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations state in no case may Federal Direct Loans awarded exceed the student's estimated costs of attendance for the period of enrollment for which the loans were intended, less (1) the student's estimated financial assistance for that period and (2) the borrower's expected family contribution for that period. Condition: For one student out of seven tested, a student was awarded two direct plus loans which caused the student's financial assistance received to be greater than the student's cost of attendance. Cause: The Organization did not award loans correctly when calculating the student's award package. Effect: The student was over-awarded $4,800 of Federal Direct Loans he or she was not eligible to receive. Questioned Costs: Questioned costs of $4,800 were noted during testing. The full population of withdraws was tested. Context: Our sample was not a statistically valid sample. Total population sampled included 32 students for $564,857 of Federal Direct Loans. Sample size was seven students for a total of $107,735 of Federal Direct Loans. Recommendation: The Organization should remit the over-awarded funds back to the Federal Direct Loan program. Additionally, the Organization should revise its procedures for awarding student financial aid to ensure that federal aid is awarded correctly and that safeguards are in place to prevent, or detect and correct, over-awarding of federal funds. Views of Responsible Official(s): Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements. The Organization has hired a new Director of Financial Aid and Student Housing who started July 1, 2022. This individual clearly understands the limitation parameter of the cost of attendance. Over-awarded funds will be remitted back to the Federal Direct Loan program.
Federal Program: Student Financial Assistance Cluster, Federal Direct Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 U.S. Code of Federal Regulations (CFR) 668.16) requires recipients of Federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition: There was not an adequate system of controls in place that would have prevented or detected potential material noncompliance matters within the Activities Allowed or Unallowed, Eligibility and Special Tests and Provisions (related to Return of Title IV Funds, Enrollment Reporting and Federal Direct Loan Disbursements) compliance requirement areas. Cause: The Organization filled its vacant director of financial aid position in the spring of 2021. It was later discovered that this person did not have the suitable skills required to effectively administer the federal financial aid programs of the Organization and this person was terminated in spring of 2022. Thus, a critical position was left vacant for part of the testing year. Effect: The potential exists that noncompliance could occur in the Activities Allowed or Unallowed, Eligibility and Special Tests and Provisions compliance areas and not be detected by the by the Organization's internal controls over compliance. Questioned Costs: There were no questioned costs associated with this finding. Context: The key position of financial aid director was vacant for part of the testing period. As of the time of our testing, this position has been filled. Recommendation: The Organization should implement procedures to ensure any individuals responsible for the oversight or review of any vendors or individuals administering financial aid are properly trained and knowledgeable of the specific requirements of Title IV. Views of Responsible Official(s): Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements. They have hired a new Director of Financial Aid and Student Housing.
Federal Program: Student Financial Assistance Cluster, Federal Direct Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations stipulate institutions are responsible for timely reporting. Under the Federal Direct Loan programs, institutions must complete and return within 15 days the enrollment reporting roster file placed in the Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by the Department of Education via the National Student Loan Data System (NSLDS). Condition: One roster file out of three tested were not completed and returned within the 15-day requirement to the NSLDS. This sample was not statistically valid. Cause: The Organization's procedures for complying with this requirement were not designed appropriately to allow for timely return of the file. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: There were no questioned costs associated with this finding. Context: The key position of financial aid director was vacant for part of the testing period. This position is responsible for reporting of the roster files. As of the time of our testing, this position has been filled. Recommendation: The Organization should revise its procedures to ensure timely completion and return of the enrollment reporting roster files. Views of Responsible Official(s): Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements. They have hired a new Director of Financial Aid and Student Housing.
Federal Program: Student Financial Assistance Cluster, Federal Direct Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations stipulate institutions must report to the National Student Loan Data System (NSLDS) when a student to whom a loan made under Title IV ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended within 30 days after the institution discovers the student's status changed, unless the institution expects to submit its next updated enrollment report within 60 days. (34 CFR 385.309(b)). Condition: For six students out of nine tested, the change in student status was not reported to the NSLDS within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. This sample was not statistically valid. Cause: The Organization's procedures for complying with this requirement were not designed appropriately to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: There were no questioned costs associated with this finding. Context: The key position of financial aid director was vacant for part of the testing period. This position is responsible for proper enrollment reporting. As of the time of our testing, this position has been filled. Recommendation: The Organization should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe. Views of Responsible Official(s): Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements. They have hired a new Director of Financial Aid and Student Housing.
Federal Program: Student Financial Assistance Cluster, Federal Direct Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations stipulate institutions must reconcile their Federal Direct Loan School Account Statements (SAS) to the institution's records each month. Condition: The Organization did not reconcile its SAS data file to its financial records for all 12 months of the fiscal year; however, the Organization did complete the annual reconciliation at the end of the fiscal year. Cause: Lack of competency and turnover in the financial aid office contributed to the Organization not being able to perform the reconciliations in the required timeframe. Effect: The potential exists that an error could occur in the financial records and not be detected and corrected within a timely manner by employees in the normal course of performing their assigned functions. Questioned Costs: There were no questioned costs associated with this finding. Context: The key position of financial aid director was vacant for part of the testing period. This position is responsible for proper enrollment reporting. As of the time of our testing, this position has been filled. Recommendation: The Organization should implement policy and procedures to ensure that the monthly SAS reconciliations are performed on a timely basis and correct all errors to adhere to federal regulations. Views of Responsible Official(s): Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements. The Organization has hired a new Director of Financial Aid and Student Housing who started July 1, 2022, who is committed to completing the reconciliations in a timely manner. Furthermore, a different individual will check and determine that the reconciliations are completed timely.
Federal Program: Student Financial Assistance Cluster, Federal Direct Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations require institutions to refund any unearned portions of grants and loans to the Title IV program within 45 days after a student withdraws Condition: Federal aid refunds were not calculated correctly for one student out of three tested and resulted in the Organization not refunding correct amounts. This was not a statistically valid sample. Cause: The Organization did not perform return of Title IV refund calculations during the year. Effect: The Organization did not refund $4,547 of Federal Direct Loans that was not earned for the student. Questioned Costs: Questioned costs of $4,547 were noted during testing. The full population of withdraws was tested. Context: Error was noted for one student out of three selected for testing. There was a total population of three students who withdrew during the fiscal year under audit that received Title IV aid. The sample was not statistically valid. Recommendation: The Organization should immediately perform a return of Title IV calculation for the student and remit a refund to the Title IV program. The Organization's personnel should implement a procedure to ensure a return of Title IV refund calculation for all students who withdraw on or before a defined point in any semester. This point should be after the 60.0 percent completion mark for fully earning Title IV funds, to ensure that these calculations capture any Title IV funds that need to be refunded. Views of Responsible Official(s): Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements. The Organization has hired a new Director of Financial Aid and Student Housing who started July 1, 2022. This individual will verify the calculation and return the funds to the Title IV program. A different individual who is knowledgeable about withdrawals will monitor to ensure any required refund is made.
Federal Program: Student Financial Assistance Cluster, Federal Direct Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations state in no case may Federal Direct Loans awarded exceed the student's estimated costs of attendance for the period of enrollment for which the loans were intended, less (1) the student's estimated financial assistance for that period and (2) the borrower's expected family contribution for that period. Condition: For one student out of seven tested, a student was awarded two direct plus loans which caused the student's financial assistance received to be greater than the student's cost of attendance. Cause: The Organization did not award loans correctly when calculating the student's award package. Effect: The student was over-awarded $4,800 of Federal Direct Loans he or she was not eligible to receive. Questioned Costs: Questioned costs of $4,800 were noted during testing. The full population of withdraws was tested. Context: Our sample was not a statistically valid sample. Total population sampled included 32 students for $564,857 of Federal Direct Loans. Sample size was seven students for a total of $107,735 of Federal Direct Loans. Recommendation: The Organization should remit the over-awarded funds back to the Federal Direct Loan program. Additionally, the Organization should revise its procedures for awarding student financial aid to ensure that federal aid is awarded correctly and that safeguards are in place to prevent, or detect and correct, over-awarding of federal funds. Views of Responsible Official(s): Management agrees with this finding and has recognized their need for a qualified individual who is knowledgeable about financial aid requirements. The Organization has hired a new Director of Financial Aid and Student Housing who started July 1, 2022. This individual clearly understands the limitation parameter of the cost of attendance. Over-awarded funds will be remitted back to the Federal Direct Loan program.