Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to Common Origination and Disbursement ("COD") 2021-2022 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. Condition The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 38 students, out of a sample of 40, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Cause The University did not have procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The University did not report the correct disbursement dates to the COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 38 students, or 95% of our sample, did not report the correct disbursement date to COD. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should have procedures to ensure that COD disbursement information matches the University 's records. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (ED) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED 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 a minimum of every 60 days. 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. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the University to report student enrollment changes to the National Student Loan Data System (NSLDS) within 60 days. During our testing, we noted 2 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The University did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The University did not report the students? status changes to NSLDS within the required timeframe, which may impact the students? loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or approximately 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 188 to 284 days. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation The University should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the University?s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (?FFEL?) program lender, an institution returns unearned Title IV, HEA program funds timely if ? (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if ? (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student?s withdrawal from the institution. The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 18, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 67-72 days. Cause The University did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The University did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 2 students, or 11% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the University is responsible for adjusting the student?s billing statement and returning unearned Title IV funds through the U.S. Department of Education?s Grant Management System (?G5?). The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 18, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The University did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. Effect The University did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $802 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 1 students, or 5% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to Common Origination and Disbursement ("COD") 2021-2022 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. Condition The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 38 students, out of a sample of 40, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Cause The University did not have procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The University did not report the correct disbursement dates to the COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 38 students, or 95% of our sample, did not report the correct disbursement date to COD. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should have procedures to ensure that COD disbursement information matches the University 's records. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (ED) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED 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 a minimum of every 60 days. 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. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the University to report student enrollment changes to the National Student Loan Data System (NSLDS) within 60 days. During our testing, we noted 2 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The University did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The University did not report the students? status changes to NSLDS within the required timeframe, which may impact the students? loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or approximately 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 188 to 284 days. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation The University should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the University?s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (?FFEL?) program lender, an institution returns unearned Title IV, HEA program funds timely if ? (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if ? (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student?s withdrawal from the institution. The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 18, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 67-72 days. Cause The University did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The University did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 2 students, or 11% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the University is responsible for adjusting the student?s billing statement and returning unearned Title IV funds through the U.S. Department of Education?s Grant Management System (?G5?). The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 18, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The University did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. Effect The University did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $802 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 1 students, or 5% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to Common Origination and Disbursement ("COD") 2021-2022 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. Condition The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 38 students, out of a sample of 40, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Cause The University did not have procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The University did not report the correct disbursement dates to the COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 38 students, or 95% of our sample, did not report the correct disbursement date to COD. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should have procedures to ensure that COD disbursement information matches the University 's records. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (ED) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED 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 a minimum of every 60 days. 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. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the University to report student enrollment changes to the National Student Loan Data System (NSLDS) within 60 days. During our testing, we noted 2 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The University did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The University did not report the students? status changes to NSLDS within the required timeframe, which may impact the students? loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or approximately 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 188 to 284 days. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation The University should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the University?s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (?FFEL?) program lender, an institution returns unearned Title IV, HEA program funds timely if ? (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if ? (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student?s withdrawal from the institution. The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 18, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 67-72 days. Cause The University did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The University did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 2 students, or 11% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the University is responsible for adjusting the student?s billing statement and returning unearned Title IV funds through the U.S. Department of Education?s Grant Management System (?G5?). The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 18, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The University did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. Effect The University did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $802 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 1 students, or 5% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to Common Origination and Disbursement ("COD") 2021-2022 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. Condition The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 38 students, out of a sample of 40, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Cause The University did not have procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The University did not report the correct disbursement dates to the COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 38 students, or 95% of our sample, did not report the correct disbursement date to COD. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should have procedures to ensure that COD disbursement information matches the University 's records. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (ED) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED 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 a minimum of every 60 days. 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. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the University to report student enrollment changes to the National Student Loan Data System (NSLDS) within 60 days. During our testing, we noted 2 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The University did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The University did not report the students? status changes to NSLDS within the required timeframe, which may impact the students? loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or approximately 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 188 to 284 days. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation The University should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the University?s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (?FFEL?) program lender, an institution returns unearned Title IV, HEA program funds timely if ? (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if ? (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student?s withdrawal from the institution. The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 18, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 67-72 days. Cause The University did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The University did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 2 students, or 11% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the University is responsible for adjusting the student?s billing statement and returning unearned Title IV funds through the U.S. Department of Education?s Grant Management System (?G5?). The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 18, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The University did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. Effect The University did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $802 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 1 students, or 5% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to Common Origination and Disbursement ("COD") 2021-2022 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. Condition The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 38 students, out of a sample of 40, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Cause The University did not have procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The University did not report the correct disbursement dates to the COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 38 students, or 95% of our sample, did not report the correct disbursement date to COD. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should have procedures to ensure that COD disbursement information matches the University 's records. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (ED) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED 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 a minimum of every 60 days. 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. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the University to report student enrollment changes to the National Student Loan Data System (NSLDS) within 60 days. During our testing, we noted 2 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The University did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The University did not report the students? status changes to NSLDS within the required timeframe, which may impact the students? loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or approximately 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 188 to 284 days. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation The University should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the University?s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (?FFEL?) program lender, an institution returns unearned Title IV, HEA program funds timely if ? (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if ? (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student?s withdrawal from the institution. The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 18, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 67-72 days. Cause The University did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The University did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 2 students, or 11% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the University is responsible for adjusting the student?s billing statement and returning unearned Title IV funds through the U.S. Department of Education?s Grant Management System (?G5?). The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 18, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The University did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. Effect The University did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $802 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 1 students, or 5% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to Common Origination and Disbursement ("COD") 2021-2022 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. Condition The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 38 students, out of a sample of 40, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Cause The University did not have procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The University did not report the correct disbursement dates to the COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 38 students, or 95% of our sample, did not report the correct disbursement date to COD. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should have procedures to ensure that COD disbursement information matches the University 's records. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (ED) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED 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 a minimum of every 60 days. 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. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the University to report student enrollment changes to the National Student Loan Data System (NSLDS) within 60 days. During our testing, we noted 2 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The University did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The University did not report the students? status changes to NSLDS within the required timeframe, which may impact the students? loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or approximately 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 188 to 284 days. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation The University should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the University?s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (?FFEL?) program lender, an institution returns unearned Title IV, HEA program funds timely if ? (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if ? (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student?s withdrawal from the institution. The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 18, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 67-72 days. Cause The University did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The University did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 2 students, or 11% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the University is responsible for adjusting the student?s billing statement and returning unearned Title IV funds through the U.S. Department of Education?s Grant Management System (?G5?). The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 18, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The University did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. Effect The University did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $802 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 1 students, or 5% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to Common Origination and Disbursement ("COD") 2021-2022 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. Condition The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 38 students, out of a sample of 40, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Cause The University did not have procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The University did not report the correct disbursement dates to the COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 38 students, or 95% of our sample, did not report the correct disbursement date to COD. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should have procedures to ensure that COD disbursement information matches the University 's records. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (ED) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED 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 a minimum of every 60 days. 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. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the University to report student enrollment changes to the National Student Loan Data System (NSLDS) within 60 days. During our testing, we noted 2 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The University did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The University did not report the students? status changes to NSLDS within the required timeframe, which may impact the students? loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or approximately 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 188 to 284 days. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation The University should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the University?s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (?FFEL?) program lender, an institution returns unearned Title IV, HEA program funds timely if ? (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if ? (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student?s withdrawal from the institution. The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 18, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 67-72 days. Cause The University did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The University did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 2 students, or 11% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the University is responsible for adjusting the student?s billing statement and returning unearned Title IV funds through the U.S. Department of Education?s Grant Management System (?G5?). The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 18, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The University did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. Effect The University did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $802 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 1 students, or 5% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to Common Origination and Disbursement ("COD") 2021-2022 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. Condition The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 38 students, out of a sample of 40, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Cause The University did not have procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The University did not report the correct disbursement dates to the COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 38 students, or 95% of our sample, did not report the correct disbursement date to COD. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should have procedures to ensure that COD disbursement information matches the University 's records. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (ED) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED 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 a minimum of every 60 days. 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. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the University to report student enrollment changes to the National Student Loan Data System (NSLDS) within 60 days. During our testing, we noted 2 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The University did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The University did not report the students? status changes to NSLDS within the required timeframe, which may impact the students? loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or approximately 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 188 to 284 days. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation The University should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the University?s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (?FFEL?) program lender, an institution returns unearned Title IV, HEA program funds timely if ? (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if ? (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student?s withdrawal from the institution. The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 18, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 67-72 days. Cause The University did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The University did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 2 students, or 11% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the University is responsible for adjusting the student?s billing statement and returning unearned Title IV funds through the U.S. Department of Education?s Grant Management System (?G5?). The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 18, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The University did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. Effect The University did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $802 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 1 students, or 5% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to Common Origination and Disbursement ("COD") 2021-2022 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. Condition The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 38 students, out of a sample of 40, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Cause The University did not have procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The University did not report the correct disbursement dates to the COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 38 students, or 95% of our sample, did not report the correct disbursement date to COD. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should have procedures to ensure that COD disbursement information matches the University 's records. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (ED) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED 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 a minimum of every 60 days. 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. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the University to report student enrollment changes to the National Student Loan Data System (NSLDS) within 60 days. During our testing, we noted 2 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The University did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The University did not report the students? status changes to NSLDS within the required timeframe, which may impact the students? loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or approximately 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 188 to 284 days. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation The University should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the University?s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (?FFEL?) program lender, an institution returns unearned Title IV, HEA program funds timely if ? (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if ? (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student?s withdrawal from the institution. The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 18, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 67-72 days. Cause The University did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The University did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 2 students, or 11% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the University is responsible for adjusting the student?s billing statement and returning unearned Title IV funds through the U.S. Department of Education?s Grant Management System (?G5?). The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 18, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The University did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. Effect The University did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $802 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 1 students, or 5% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to Common Origination and Disbursement ("COD") 2021-2022 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. Condition The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 38 students, out of a sample of 40, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Cause The University did not have procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The University did not report the correct disbursement dates to the COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 38 students, or 95% of our sample, did not report the correct disbursement date to COD. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should have procedures to ensure that COD disbursement information matches the University 's records. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (ED) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED 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 a minimum of every 60 days. 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. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the University to report student enrollment changes to the National Student Loan Data System (NSLDS) within 60 days. During our testing, we noted 2 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The University did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The University did not report the students? status changes to NSLDS within the required timeframe, which may impact the students? loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or approximately 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 188 to 284 days. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation The University should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the University?s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (?FFEL?) program lender, an institution returns unearned Title IV, HEA program funds timely if ? (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if ? (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student?s withdrawal from the institution. The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 18, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 67-72 days. Cause The University did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The University did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 2 students, or 11% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The University agrees with the finding.
Finding number: 2022-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the University is responsible for adjusting the student?s billing statement and returning unearned Title IV funds through the U.S. Department of Education?s Grant Management System (?G5?). The University has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 18, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The University did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. Effect The University did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $802 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 18 students selected for testing, 1 students, or 5% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The University agrees with the finding.