2022-001 Returns of Title IV Funds Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 Criteria 34 CFR 668.22(j): (1) An institution must return the amount of Title IV funds as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew (2) For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate; (ii) Academic year in which the student withdrew; or (iii) Educational program from which the student withdrew. Condition Through our testing of 16 students who were awarded Title IV aid and withdrew from the University, we noted the following: ? 2 instances where the student funds were not returned timely. More specifically, it was 52 days from when the 2 students withdrew from the University that the funds were returned and thus they were 7 days late. ? 6 instances where the Return of Title IV funds calculations were performed, but not subject to a second level of review and approval. Cause The University relies on PowerFaids to process the return of Title IV (R2T4) funds and has policies and procedures in place requiring a review of the calculation to be evidenced within PowerFaids. The University identified an issue in PowerFaids where the system was not identifying disbursements (and change of disbursements) for R2T4 students. Once the system issue was identified by management, they manually uploaded the R2T4 students to PowerFaids for disbursement to the federal government. However, the University did not have sufficient controls in place to ensure that the review of the Title IV return calculations were performed and the Title IV returns were issued timely. Effect The lack of timeliness or accuracy in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back to the federal government. Questioned Costs None identified. Recommendation We recommend that the University implement a control to monitor the processing and management of Title IV returns to ensure that the refunds are completed timely. Management?s Views and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-002 Borrower data and reconciliation reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 Criteria 34 CFR 685.300(b)(5): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to - On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition Through our testing of 3 Student Account Statement (SAS) reconciliations, we noted 1 instance where the SAS reconciliation was not performed. Cause The University did not have sufficient oversight over the personnel who was performing the SAS reconciliations from the summer leading up to the 2021-2022 academic year through March 2022. As a result, the September 2021 disbursements were not reconciled and the University did not have the appropriate controls in place to identify that the reconciliation was not performed. Effect Without the appropriate reconciliation of direct loan disbursements, the University has an increased risk that federal funding disbursed will not be effectively managed and expended in accordance with the terms and conditions of its agreement with the federal agency. Questioned Costs None identified. Recommendation We recommend that the University implement a second level of review to ensure that SAS reconciliations are prepared and reviewed on a timely basis. Management?s Views and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-003 Enrollment reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans, Federal Pell Grant Program Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Numbers: 84.268, 84.063 Criteria Federal regulations governing Title IV student aid programs require institutions, lenders, Government Agencies, and the Direct Loan Servicer to monitor and update the enrollment status of students who receive Federal student loans. Completion of Enrollment Reporting satisfies the regulatory requirements for schools. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (?NSLDS?). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (Direct Loan, 34 CFR section 685.309). The school remains responsible for submitting timely, accurate, and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with Federal Regulation 34 CFR 682.610(c). Condition Through our testing of 25 enrollment status changes, we noted the following: ? 9 instances where a student?s status was not reported timely to the National Student Clearinghouse (?NSC?). As the change in status was not reported in a timely manner to NSC by the University, that information was not transmitted to the NSLDS timely. As a result, it was between 129-238 days from when the status change was reported by the University to NSC to when NSLDS received the status change. ? 7 instances where the student?s change type per the student?s file did not agree to the NSLDS campus level reporting. ? 8 instances where the student?s change type per the student?s file did not agree to the NSLDS program level reporting. Cause The University implemented a new student information system, Workday Student, during FY22. The University relied upon Workday Student to upload the student status changes to NSC, which then sends the information to NSLDS. As a result of the system implementation, coding errors within Workday Student resulted in errors in the Degree Files, which prevented the NSC from processing the student status changes. The most common error related to students who had multiple branches on their enrollment record on NSC. NSC was not able to process which branch the ?Graduated? status should be applied to, leading to manual application of the status via the Error Report. The University was notified of the errors via email in the Error Report. However, due to turnover at the end of December 2021, those Error Reports were not received by the secondary employee who assumed the role. The issue was identified by management in August 2022 and coordinated with Workday Student specialists to remediate the issue. However, they did not have sufficient personnel due to turnover to identify and remediate the issue timely. Additionally, the University did not have sufficient controls in place to monitor that student status changes are communicated to NSC timely. Effect The effective administration of Title IV loans could be impacted when changes in students? status are not reported timely and accurately. The accuracy of enrollment information is important as the student?s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Government?s payment of interest subsidies. Questioned Costs None identified. Recommendation We recommend the University implement a control to ensure the completeness and accuracy of the information that is transmitted from Workday Student to the NSC and ultimately to NSLDS. Management?s Views and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-003 Enrollment reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans, Federal Pell Grant Program Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Numbers: 84.268, 84.063 Criteria Federal regulations governing Title IV student aid programs require institutions, lenders, Government Agencies, and the Direct Loan Servicer to monitor and update the enrollment status of students who receive Federal student loans. Completion of Enrollment Reporting satisfies the regulatory requirements for schools. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (?NSLDS?). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (Direct Loan, 34 CFR section 685.309). The school remains responsible for submitting timely, accurate, and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with Federal Regulation 34 CFR 682.610(c). Condition Through our testing of 25 enrollment status changes, we noted the following: ? 9 instances where a student?s status was not reported timely to the National Student Clearinghouse (?NSC?). As the change in status was not reported in a timely manner to NSC by the University, that information was not transmitted to the NSLDS timely. As a result, it was between 129-238 days from when the status change was reported by the University to NSC to when NSLDS received the status change. ? 7 instances where the student?s change type per the student?s file did not agree to the NSLDS campus level reporting. ? 8 instances where the student?s change type per the student?s file did not agree to the NSLDS program level reporting. Cause The University implemented a new student information system, Workday Student, during FY22. The University relied upon Workday Student to upload the student status changes to NSC, which then sends the information to NSLDS. As a result of the system implementation, coding errors within Workday Student resulted in errors in the Degree Files, which prevented the NSC from processing the student status changes. The most common error related to students who had multiple branches on their enrollment record on NSC. NSC was not able to process which branch the ?Graduated? status should be applied to, leading to manual application of the status via the Error Report. The University was notified of the errors via email in the Error Report. However, due to turnover at the end of December 2021, those Error Reports were not received by the secondary employee who assumed the role. The issue was identified by management in August 2022 and coordinated with Workday Student specialists to remediate the issue. However, they did not have sufficient personnel due to turnover to identify and remediate the issue timely. Additionally, the University did not have sufficient controls in place to monitor that student status changes are communicated to NSC timely. Effect The effective administration of Title IV loans could be impacted when changes in students? status are not reported timely and accurately. The accuracy of enrollment information is important as the student?s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Government?s payment of interest subsidies. Questioned Costs None identified. Recommendation We recommend the University implement a control to ensure the completeness and accuracy of the information that is transmitted from Workday Student to the NSC and ultimately to NSLDS. Management?s Views and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 Returns of Title IV Funds Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 Criteria 34 CFR 668.22(j): (1) An institution must return the amount of Title IV funds as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew (2) For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate; (ii) Academic year in which the student withdrew; or (iii) Educational program from which the student withdrew. Condition Through our testing of 16 students who were awarded Title IV aid and withdrew from the University, we noted the following: ? 2 instances where the student funds were not returned timely. More specifically, it was 52 days from when the 2 students withdrew from the University that the funds were returned and thus they were 7 days late. ? 6 instances where the Return of Title IV funds calculations were performed, but not subject to a second level of review and approval. Cause The University relies on PowerFaids to process the return of Title IV (R2T4) funds and has policies and procedures in place requiring a review of the calculation to be evidenced within PowerFaids. The University identified an issue in PowerFaids where the system was not identifying disbursements (and change of disbursements) for R2T4 students. Once the system issue was identified by management, they manually uploaded the R2T4 students to PowerFaids for disbursement to the federal government. However, the University did not have sufficient controls in place to ensure that the review of the Title IV return calculations were performed and the Title IV returns were issued timely. Effect The lack of timeliness or accuracy in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back to the federal government. Questioned Costs None identified. Recommendation We recommend that the University implement a control to monitor the processing and management of Title IV returns to ensure that the refunds are completed timely. Management?s Views and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-002 Borrower data and reconciliation reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 Criteria 34 CFR 685.300(b)(5): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to - On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition Through our testing of 3 Student Account Statement (SAS) reconciliations, we noted 1 instance where the SAS reconciliation was not performed. Cause The University did not have sufficient oversight over the personnel who was performing the SAS reconciliations from the summer leading up to the 2021-2022 academic year through March 2022. As a result, the September 2021 disbursements were not reconciled and the University did not have the appropriate controls in place to identify that the reconciliation was not performed. Effect Without the appropriate reconciliation of direct loan disbursements, the University has an increased risk that federal funding disbursed will not be effectively managed and expended in accordance with the terms and conditions of its agreement with the federal agency. Questioned Costs None identified. Recommendation We recommend that the University implement a second level of review to ensure that SAS reconciliations are prepared and reviewed on a timely basis. Management?s Views and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-003 Enrollment reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans, Federal Pell Grant Program Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Numbers: 84.268, 84.063 Criteria Federal regulations governing Title IV student aid programs require institutions, lenders, Government Agencies, and the Direct Loan Servicer to monitor and update the enrollment status of students who receive Federal student loans. Completion of Enrollment Reporting satisfies the regulatory requirements for schools. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (?NSLDS?). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (Direct Loan, 34 CFR section 685.309). The school remains responsible for submitting timely, accurate, and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with Federal Regulation 34 CFR 682.610(c). Condition Through our testing of 25 enrollment status changes, we noted the following: ? 9 instances where a student?s status was not reported timely to the National Student Clearinghouse (?NSC?). As the change in status was not reported in a timely manner to NSC by the University, that information was not transmitted to the NSLDS timely. As a result, it was between 129-238 days from when the status change was reported by the University to NSC to when NSLDS received the status change. ? 7 instances where the student?s change type per the student?s file did not agree to the NSLDS campus level reporting. ? 8 instances where the student?s change type per the student?s file did not agree to the NSLDS program level reporting. Cause The University implemented a new student information system, Workday Student, during FY22. The University relied upon Workday Student to upload the student status changes to NSC, which then sends the information to NSLDS. As a result of the system implementation, coding errors within Workday Student resulted in errors in the Degree Files, which prevented the NSC from processing the student status changes. The most common error related to students who had multiple branches on their enrollment record on NSC. NSC was not able to process which branch the ?Graduated? status should be applied to, leading to manual application of the status via the Error Report. The University was notified of the errors via email in the Error Report. However, due to turnover at the end of December 2021, those Error Reports were not received by the secondary employee who assumed the role. The issue was identified by management in August 2022 and coordinated with Workday Student specialists to remediate the issue. However, they did not have sufficient personnel due to turnover to identify and remediate the issue timely. Additionally, the University did not have sufficient controls in place to monitor that student status changes are communicated to NSC timely. Effect The effective administration of Title IV loans could be impacted when changes in students? status are not reported timely and accurately. The accuracy of enrollment information is important as the student?s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Government?s payment of interest subsidies. Questioned Costs None identified. Recommendation We recommend the University implement a control to ensure the completeness and accuracy of the information that is transmitted from Workday Student to the NSC and ultimately to NSLDS. Management?s Views and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-003 Enrollment reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans, Federal Pell Grant Program Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Numbers: 84.268, 84.063 Criteria Federal regulations governing Title IV student aid programs require institutions, lenders, Government Agencies, and the Direct Loan Servicer to monitor and update the enrollment status of students who receive Federal student loans. Completion of Enrollment Reporting satisfies the regulatory requirements for schools. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (?NSLDS?). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (Direct Loan, 34 CFR section 685.309). The school remains responsible for submitting timely, accurate, and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with Federal Regulation 34 CFR 682.610(c). Condition Through our testing of 25 enrollment status changes, we noted the following: ? 9 instances where a student?s status was not reported timely to the National Student Clearinghouse (?NSC?). As the change in status was not reported in a timely manner to NSC by the University, that information was not transmitted to the NSLDS timely. As a result, it was between 129-238 days from when the status change was reported by the University to NSC to when NSLDS received the status change. ? 7 instances where the student?s change type per the student?s file did not agree to the NSLDS campus level reporting. ? 8 instances where the student?s change type per the student?s file did not agree to the NSLDS program level reporting. Cause The University implemented a new student information system, Workday Student, during FY22. The University relied upon Workday Student to upload the student status changes to NSC, which then sends the information to NSLDS. As a result of the system implementation, coding errors within Workday Student resulted in errors in the Degree Files, which prevented the NSC from processing the student status changes. The most common error related to students who had multiple branches on their enrollment record on NSC. NSC was not able to process which branch the ?Graduated? status should be applied to, leading to manual application of the status via the Error Report. The University was notified of the errors via email in the Error Report. However, due to turnover at the end of December 2021, those Error Reports were not received by the secondary employee who assumed the role. The issue was identified by management in August 2022 and coordinated with Workday Student specialists to remediate the issue. However, they did not have sufficient personnel due to turnover to identify and remediate the issue timely. Additionally, the University did not have sufficient controls in place to monitor that student status changes are communicated to NSC timely. Effect The effective administration of Title IV loans could be impacted when changes in students? status are not reported timely and accurately. The accuracy of enrollment information is important as the student?s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Government?s payment of interest subsidies. Questioned Costs None identified. Recommendation We recommend the University implement a control to ensure the completeness and accuracy of the information that is transmitted from Workday Student to the NSC and ultimately to NSLDS. Management?s Views and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.