FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.
FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 1087lI] COST OF ATTENDANCE. For the purpose of this title, the term ``cost of attendance?? means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context ? We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2022. We obtained the students? cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Six of the selected students had cost of attendance that included the incorrect budget for fees. Cause ? The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. - Effect ? The students? financial need is calculated based on the students? expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student?s award offers. If the cost of attendance is incorrect, this could result in an over- or under award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding ? This is a repeat finding. See 2021-003 Recommendation ? We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. - Views of responsible officials and planned corrective actions ? In order to simplify the awarding process, in June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.
FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 1087lI] COST OF ATTENDANCE. For the purpose of this title, the term ``cost of attendance?? means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context ? We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2022. We obtained the students? cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Six of the selected students had cost of attendance that included the incorrect budget for fees. Cause ? The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. - Effect ? The students? financial need is calculated based on the students? expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student?s award offers. If the cost of attendance is incorrect, this could result in an over- or under award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding ? This is a repeat finding. See 2021-003 Recommendation ? We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. - Views of responsible officials and planned corrective actions ? In order to simplify the awarding process, in June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.
FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 1087lI] COST OF ATTENDANCE. For the purpose of this title, the term ``cost of attendance?? means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context ? We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2022. We obtained the students? cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Six of the selected students had cost of attendance that included the incorrect budget for fees. Cause ? The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. - Effect ? The students? financial need is calculated based on the students? expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student?s award offers. If the cost of attendance is incorrect, this could result in an over- or under award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding ? This is a repeat finding. See 2021-003 Recommendation ? We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. - Views of responsible officials and planned corrective actions ? In order to simplify the awarding process, in June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.
FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 1087lI] COST OF ATTENDANCE. For the purpose of this title, the term ``cost of attendance?? means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context ? We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2022. We obtained the students? cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Six of the selected students had cost of attendance that included the incorrect budget for fees. Cause ? The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. - Effect ? The students? financial need is calculated based on the students? expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student?s award offers. If the cost of attendance is incorrect, this could result in an over- or under award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding ? This is a repeat finding. See 2021-003 Recommendation ? We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. - Views of responsible officials and planned corrective actions ? In order to simplify the awarding process, in June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.
FINDING 2022-002 ? Special Tests and Provisions ? Enrollment Reporting: Material Weakness in Internal Control - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART. - Criteria ? 34 CFR section 685.309(b)(2): Unless 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. Condition/context ? A sample of 75 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per NU?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 75 students whom had a change in address, graduated, or withdrew, 19 were not reported to the NSLDS within the required timeframe. Of the 75 students, 3 had an incorrect effective date reported to the NSLDS. Cause ? The attendance queries periodically used for change of status purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding ? This is a repeat finding. See 2021-002. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. Views of responsible officials and planned corrective actions ? In January of 2023, NU updated its NSLDS reporting policies and procedures overseen by Jorge Salas from our registrar team. The Quality Assurance, under Brandy Baker, team began reviewing enrollment reporting on a regular basis in February of 2023 to confirm the reporting process is consistent with the Title IV regulation. In the event that the Quality Assurance review yields inaccurate reporting, the Quality Assurance team will lead the investigation to determine the cause of the inaccurate reporting and will work with the appropriate departments and teams to ensure that any required corrections to process, reporting, reporting code or systems is rectified. NU reviewed and confirmed that the revised reporting logic would accurately report enrollment statuses, effective dates, and locations.
FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 1087lI] COST OF ATTENDANCE. For the purpose of this title, the term ``cost of attendance?? means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context ? We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2022. We obtained the students? cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Six of the selected students had cost of attendance that included the incorrect budget for fees. Cause ? The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. - Effect ? The students? financial need is calculated based on the students? expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student?s award offers. If the cost of attendance is incorrect, this could result in an over- or under award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding ? This is a repeat finding. See 2021-003 Recommendation ? We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. - Views of responsible officials and planned corrective actions ? In order to simplify the awarding process, in June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.
FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 1087lI] COST OF ATTENDANCE. For the purpose of this title, the term ``cost of attendance?? means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context ? We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2022. We obtained the students? cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Six of the selected students had cost of attendance that included the incorrect budget for fees. Cause ? The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. - Effect ? The students? financial need is calculated based on the students? expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student?s award offers. If the cost of attendance is incorrect, this could result in an over- or under award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding ? This is a repeat finding. See 2021-003 Recommendation ? We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. - Views of responsible officials and planned corrective actions ? In order to simplify the awarding process, in June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.
FINDING 2022-004 ? Reporting ? Material Weakness in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? 86 CFR 26213 requires Education Stabilization Fund recipients to post the required quarterly information to their website within 10 days of the end of the quarter in which the funds were spent. Public quarterly reports should remain online for a period of at least three years after the submission of the last quarterly or annual performance report. Condition/context ? Although NU could produce documentation to evidence the periodic updating of its website such as contemporaneous email communication, all previously posted reports prior to the report current as of the timing of our audit could not readily be produced nor could evidence of the review and approval of such reports be produced. NU also was unable to demonstrate that it timely reported the quarterly information to its website. - Questioned costs ? No questioned costs were identified as part of this finding. Cause ? The exceptions occurred as a result of the lack of internal controls in place to 1) track reporting requirements including the due date per federal regulations, and 2) supervisory review and approval of prepared reports, prior to submittal. Effect or potential effect ? The required quarterly institutional and student reporting was not posted to NU?s website within the timeframe required by the conditions of the grant. Repeat finding ? This is a repeat finding. See 2021-004 Recommendation ? We recommend that NU implement a tracking mechanism for reporting requirements including establishing timetables and responsible parties to complete the reports and review the reports. - Views of responsible officials and planned corrective actions ? NU has updated its HEERF reporting process to include a documented checklist review from the Quality Assurance team, under Brandy Baker, before the report is submitted to demonstrate internal controls and accuracy. NU has created a HEERF report repository that will house historical and current reports. In March of 2023, NU developed a reporting process timeline to better support the collection, processing, and reporting of the data in an effort to prevent submission delays managed by Ernie Prunker, Sr. Director Account Services.
FINDING 2022-004 ? Reporting ? Material Weakness in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? 86 CFR 26213 requires Education Stabilization Fund recipients to post the required quarterly information to their website within 10 days of the end of the quarter in which the funds were spent. Public quarterly reports should remain online for a period of at least three years after the submission of the last quarterly or annual performance report. Condition/context ? Although NU could produce documentation to evidence the periodic updating of its website such as contemporaneous email communication, all previously posted reports prior to the report current as of the timing of our audit could not readily be produced nor could evidence of the review and approval of such reports be produced. NU also was unable to demonstrate that it timely reported the quarterly information to its website. - Questioned costs ? No questioned costs were identified as part of this finding. Cause ? The exceptions occurred as a result of the lack of internal controls in place to 1) track reporting requirements including the due date per federal regulations, and 2) supervisory review and approval of prepared reports, prior to submittal. Effect or potential effect ? The required quarterly institutional and student reporting was not posted to NU?s website within the timeframe required by the conditions of the grant. Repeat finding ? This is a repeat finding. See 2021-004 Recommendation ? We recommend that NU implement a tracking mechanism for reporting requirements including establishing timetables and responsible parties to complete the reports and review the reports. - Views of responsible officials and planned corrective actions ? NU has updated its HEERF reporting process to include a documented checklist review from the Quality Assurance team, under Brandy Baker, before the report is submitted to demonstrate internal controls and accuracy. NU has created a HEERF report repository that will house historical and current reports. In March of 2023, NU developed a reporting process timeline to better support the collection, processing, and reporting of the data in an effort to prevent submission delays managed by Ernie Prunker, Sr. Director Account Services.
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.
FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 1087lI] COST OF ATTENDANCE. For the purpose of this title, the term ``cost of attendance?? means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context ? We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2022. We obtained the students? cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Six of the selected students had cost of attendance that included the incorrect budget for fees. Cause ? The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. - Effect ? The students? financial need is calculated based on the students? expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student?s award offers. If the cost of attendance is incorrect, this could result in an over- or under award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding ? This is a repeat finding. See 2021-003 Recommendation ? We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. - Views of responsible officials and planned corrective actions ? In order to simplify the awarding process, in June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.
FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 1087lI] COST OF ATTENDANCE. For the purpose of this title, the term ``cost of attendance?? means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context ? We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2022. We obtained the students? cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Six of the selected students had cost of attendance that included the incorrect budget for fees. Cause ? The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. - Effect ? The students? financial need is calculated based on the students? expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student?s award offers. If the cost of attendance is incorrect, this could result in an over- or under award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding ? This is a repeat finding. See 2021-003 Recommendation ? We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. - Views of responsible officials and planned corrective actions ? In order to simplify the awarding process, in June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.
FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 1087lI] COST OF ATTENDANCE. For the purpose of this title, the term ``cost of attendance?? means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context ? We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2022. We obtained the students? cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Six of the selected students had cost of attendance that included the incorrect budget for fees. Cause ? The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. - Effect ? The students? financial need is calculated based on the students? expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student?s award offers. If the cost of attendance is incorrect, this could result in an over- or under award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding ? This is a repeat finding. See 2021-003 Recommendation ? We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. - Views of responsible officials and planned corrective actions ? In order to simplify the awarding process, in June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.
FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 1087lI] COST OF ATTENDANCE. For the purpose of this title, the term ``cost of attendance?? means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context ? We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2022. We obtained the students? cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Six of the selected students had cost of attendance that included the incorrect budget for fees. Cause ? The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. - Effect ? The students? financial need is calculated based on the students? expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student?s award offers. If the cost of attendance is incorrect, this could result in an over- or under award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding ? This is a repeat finding. See 2021-003 Recommendation ? We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. - Views of responsible officials and planned corrective actions ? In order to simplify the awarding process, in June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.
FINDING 2022-002 ? Special Tests and Provisions ? Enrollment Reporting: Material Weakness in Internal Control - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART. - Criteria ? 34 CFR section 685.309(b)(2): Unless 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. Condition/context ? A sample of 75 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per NU?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 75 students whom had a change in address, graduated, or withdrew, 19 were not reported to the NSLDS within the required timeframe. Of the 75 students, 3 had an incorrect effective date reported to the NSLDS. Cause ? The attendance queries periodically used for change of status purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding ? This is a repeat finding. See 2021-002. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. Views of responsible officials and planned corrective actions ? In January of 2023, NU updated its NSLDS reporting policies and procedures overseen by Jorge Salas from our registrar team. The Quality Assurance, under Brandy Baker, team began reviewing enrollment reporting on a regular basis in February of 2023 to confirm the reporting process is consistent with the Title IV regulation. In the event that the Quality Assurance review yields inaccurate reporting, the Quality Assurance team will lead the investigation to determine the cause of the inaccurate reporting and will work with the appropriate departments and teams to ensure that any required corrections to process, reporting, reporting code or systems is rectified. NU reviewed and confirmed that the revised reporting logic would accurately report enrollment statuses, effective dates, and locations.
FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 1087lI] COST OF ATTENDANCE. For the purpose of this title, the term ``cost of attendance?? means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context ? We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2022. We obtained the students? cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Six of the selected students had cost of attendance that included the incorrect budget for fees. Cause ? The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. - Effect ? The students? financial need is calculated based on the students? expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student?s award offers. If the cost of attendance is incorrect, this could result in an over- or under award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding ? This is a repeat finding. See 2021-003 Recommendation ? We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. - Views of responsible officials and planned corrective actions ? In order to simplify the awarding process, in June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.
FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? SEC. 472 of the Higher Education Act (HEA) [20 U.S.C. 1087lI] COST OF ATTENDANCE. For the purpose of this title, the term ``cost of attendance?? means: (1) tuition and fees normally assessed a student carrying the same academic workload as determined by the institution and including costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study. Condition/context ? We selected 40 students from a list of all students enrolled and awarded federal student aid in fiscal year 2022. We obtained the students? cost of attendance calculations and compared them to their established cost of attendance policy, published tuition rates, and other supporting documents. Six of the selected students had cost of attendance that included the incorrect budget for fees. Cause ? The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. - Effect ? The students? financial need is calculated based on the students? expected family contribution and estimated cost of attendance, which in turn is used to determine eligibility for programs and packages the student?s award offers. If the cost of attendance is incorrect, this could result in an over- or under award. In our testing, we did not identify students who were over-awarded or under-awarded resulting from this specific condition. Repeat finding ? This is a repeat finding. See 2021-003 Recommendation ? We recommend NU institute a process and control to ensure student cost of attendance budgets are reviewed by the appropriate person(s) in a timely manner and that the review is documented. - Views of responsible officials and planned corrective actions ? In order to simplify the awarding process, in June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.
FINDING 2022-004 ? Reporting ? Material Weakness in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? 86 CFR 26213 requires Education Stabilization Fund recipients to post the required quarterly information to their website within 10 days of the end of the quarter in which the funds were spent. Public quarterly reports should remain online for a period of at least three years after the submission of the last quarterly or annual performance report. Condition/context ? Although NU could produce documentation to evidence the periodic updating of its website such as contemporaneous email communication, all previously posted reports prior to the report current as of the timing of our audit could not readily be produced nor could evidence of the review and approval of such reports be produced. NU also was unable to demonstrate that it timely reported the quarterly information to its website. - Questioned costs ? No questioned costs were identified as part of this finding. Cause ? The exceptions occurred as a result of the lack of internal controls in place to 1) track reporting requirements including the due date per federal regulations, and 2) supervisory review and approval of prepared reports, prior to submittal. Effect or potential effect ? The required quarterly institutional and student reporting was not posted to NU?s website within the timeframe required by the conditions of the grant. Repeat finding ? This is a repeat finding. See 2021-004 Recommendation ? We recommend that NU implement a tracking mechanism for reporting requirements including establishing timetables and responsible parties to complete the reports and review the reports. - Views of responsible officials and planned corrective actions ? NU has updated its HEERF reporting process to include a documented checklist review from the Quality Assurance team, under Brandy Baker, before the report is submitted to demonstrate internal controls and accuracy. NU has created a HEERF report repository that will house historical and current reports. In March of 2023, NU developed a reporting process timeline to better support the collection, processing, and reporting of the data in an effort to prevent submission delays managed by Ernie Prunker, Sr. Director Account Services.
FINDING 2022-004 ? Reporting ? Material Weakness in Internal Control over Compliance - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHARTS. - Criteria ? 86 CFR 26213 requires Education Stabilization Fund recipients to post the required quarterly information to their website within 10 days of the end of the quarter in which the funds were spent. Public quarterly reports should remain online for a period of at least three years after the submission of the last quarterly or annual performance report. Condition/context ? Although NU could produce documentation to evidence the periodic updating of its website such as contemporaneous email communication, all previously posted reports prior to the report current as of the timing of our audit could not readily be produced nor could evidence of the review and approval of such reports be produced. NU also was unable to demonstrate that it timely reported the quarterly information to its website. - Questioned costs ? No questioned costs were identified as part of this finding. Cause ? The exceptions occurred as a result of the lack of internal controls in place to 1) track reporting requirements including the due date per federal regulations, and 2) supervisory review and approval of prepared reports, prior to submittal. Effect or potential effect ? The required quarterly institutional and student reporting was not posted to NU?s website within the timeframe required by the conditions of the grant. Repeat finding ? This is a repeat finding. See 2021-004 Recommendation ? We recommend that NU implement a tracking mechanism for reporting requirements including establishing timetables and responsible parties to complete the reports and review the reports. - Views of responsible officials and planned corrective actions ? NU has updated its HEERF reporting process to include a documented checklist review from the Quality Assurance team, under Brandy Baker, before the report is submitted to demonstrate internal controls and accuracy. NU has created a HEERF report repository that will house historical and current reports. In March of 2023, NU developed a reporting process timeline to better support the collection, processing, and reporting of the data in an effort to prevent submission delays managed by Ernie Prunker, Sr. Director Account Services.