DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- COVID-19 Higher Education Emergency Relief Fund (HEERF COMPLIANCE and INTERNAL CONTROL FINDING 2022-003 Condition: The University was not able to provide all supporting documentation for the HEERF annual report that was submitted to the Department of Education for calendar year 2021. Criteria The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Cause: The University experienced turn-over in personnel responsible for performing the periodic and annual reporting for the HEERF funding requirements and the responsibilities were not properly communicated during the transition. Effect: The University did not have the appropriate support and source documentation to substantiate the information contained in the annual report. Recommendation: We recommend that the University maintain a file for all periodic and annual reporting to contain and preserve all supporting information and documentation to back up the number and disclosures in each report. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- COVID-19 Higher Education Emergency Relief Fund (HEERF COMPLIANCE and INTERNAL CONTROL FINDING 2022-003 Condition: The University was not able to provide all supporting documentation for the HEERF annual report that was submitted to the Department of Education for calendar year 2021. Criteria The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Cause: The University experienced turn-over in personnel responsible for performing the periodic and annual reporting for the HEERF funding requirements and the responsibilities were not properly communicated during the transition. Effect: The University did not have the appropriate support and source documentation to substantiate the information contained in the annual report. Recommendation: We recommend that the University maintain a file for all periodic and annual reporting to contain and preserve all supporting information and documentation to back up the number and disclosures in each report. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. 34 C.F.R. ? 685.304 (b)(1). If a student borrower withdraws from school without the school?s prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- COVID-19 Higher Education Emergency Relief Fund (HEERF COMPLIANCE and INTERNAL CONTROL FINDING 2022-003 Condition: The University was not able to provide all supporting documentation for the HEERF annual report that was submitted to the Department of Education for calendar year 2021. Criteria The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Cause: The University experienced turn-over in personnel responsible for performing the periodic and annual reporting for the HEERF funding requirements and the responsibilities were not properly communicated during the transition. Effect: The University did not have the appropriate support and source documentation to substantiate the information contained in the annual report. Recommendation: We recommend that the University maintain a file for all periodic and annual reporting to contain and preserve all supporting information and documentation to back up the number and disclosures in each report. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan
DEPARTMENT OF EDUCATION- COVID-19 Higher Education Emergency Relief Fund (HEERF COMPLIANCE and INTERNAL CONTROL FINDING 2022-003 Condition: The University was not able to provide all supporting documentation for the HEERF annual report that was submitted to the Department of Education for calendar year 2021. Criteria The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Cause: The University experienced turn-over in personnel responsible for performing the periodic and annual reporting for the HEERF funding requirements and the responsibilities were not properly communicated during the transition. Effect: The University did not have the appropriate support and source documentation to substantiate the information contained in the annual report. Recommendation: We recommend that the University maintain a file for all periodic and annual reporting to contain and preserve all supporting information and documentation to back up the number and disclosures in each report. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan