Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 5 of 9 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: Corrective action was taken. While verification was completed properly for each selected student, when changes were not required to the ISIRs of the students, ISIRs were not consistently released to COD. Now that the University is fully operating with its new financial aid system, JFA, we are running a daily process sending up ISIR corrections to COD for all students. Thorough review and training sessions on the verification process have been held with the financial aid team and we will continue to diligently monitor the verification process, including obtaining necessary documentation from students selected for verification and processing ISIR corrections.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 5 of 9 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: Corrective action was taken. While verification was completed properly for each selected student, when changes were not required to the ISIRs of the students, ISIRs were not consistently released to COD. Now that the University is fully operating with its new financial aid system, JFA, we are running a daily process sending up ISIR corrections to COD for all students. Thorough review and training sessions on the verification process have been held with the financial aid team and we will continue to diligently monitor the verification process, including obtaining necessary documentation from students selected for verification and processing ISIR corrections.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: L. Reporting ? Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the ?ED?) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: Certain student disbursements were not reported to COD within 15 calendar days as required; certain disbursement records did not reflect the actual disbursement date. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the COD reporting requirements. Questioned Costs: None. Context: For 2 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days. For 1 of 25 Pell disbursement records tested, the actual disbursement date was not accurately reported to COD. For 1 of 25 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days. For 1 of 25 Direct Loan disbursement records tested, the actual disbursement date was not accurately reported to COD. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely and accurate reporting to COD. Views of Responsible Officials: Corrective action was taken. The University has since transitioned to a new Financial Aid processing system, Jenzabar Financial Aid (JFA), that automatically sends updates daily, making regular uploads of files to COD much simpler.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 5 of 9 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: Corrective action was taken. While verification was completed properly for each selected student, when changes were not required to the ISIRs of the students, ISIRs were not consistently released to COD. Now that the University is fully operating with its new financial aid system, JFA, we are running a daily process sending up ISIR corrections to COD for all students. Thorough review and training sessions on the verification process have been held with the financial aid team and we will continue to diligently monitor the verification process, including obtaining necessary documentation from students selected for verification and processing ISIR corrections.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code ? The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. Condition: Campus Level: Certain students? enrollment status changes were not reported or were reported outside of the required timeframe. Program Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not certify the student?s enrollment data within 60 days. For 9 of 40 campus level records tested, the University did not notify the Department of the students? enrollment changes. For 12 of 40 campus level records tested, the University did not accurately report the students? enrollment effective dates. For 18 of 25 program level records tested, the University did not accurately report one or more significant data elements to NSLDS. 1 of 6 Enrollment Reporting roster files received during the year was not completed and returned within 15 days. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-002. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students? enrollment statuses are reported accurately and timely to NSLDS. Views of Responsible Officials: Corrective action was taken. The financial aid team is working in tandem with the Registrar?s Office and the IT department to report enrollment information via the National Student Clearinghouse (NSC). This will be up and running by June 2023, enabling timely reporting of future enrollment status changes to NSLDS.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: L. Reporting ? Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the ?ED?) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: Certain student disbursements were not reported to COD within 15 calendar days as required; certain disbursement records did not reflect the actual disbursement date. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the COD reporting requirements. Questioned Costs: None. Context: For 2 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days. For 1 of 25 Pell disbursement records tested, the actual disbursement date was not accurately reported to COD. For 1 of 25 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days. For 1 of 25 Direct Loan disbursement records tested, the actual disbursement date was not accurately reported to COD. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely and accurate reporting to COD. Views of Responsible Officials: Corrective action was taken. The University has since transitioned to a new Financial Aid processing system, Jenzabar Financial Aid (JFA), that automatically sends updates daily, making regular uploads of files to COD much simpler.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 5 of 9 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: Corrective action was taken. While verification was completed properly for each selected student, when changes were not required to the ISIRs of the students, ISIRs were not consistently released to COD. Now that the University is fully operating with its new financial aid system, JFA, we are running a daily process sending up ISIR corrections to COD for all students. Thorough review and training sessions on the verification process have been held with the financial aid team and we will continue to diligently monitor the verification process, including obtaining necessary documentation from students selected for verification and processing ISIR corrections.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code ? The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. Condition: Campus Level: Certain students? enrollment status changes were not reported or were reported outside of the required timeframe. Program Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not certify the student?s enrollment data within 60 days. For 9 of 40 campus level records tested, the University did not notify the Department of the students? enrollment changes. For 12 of 40 campus level records tested, the University did not accurately report the students? enrollment effective dates. For 18 of 25 program level records tested, the University did not accurately report one or more significant data elements to NSLDS. 1 of 6 Enrollment Reporting roster files received during the year was not completed and returned within 15 days. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-002. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students? enrollment statuses are reported accurately and timely to NSLDS. Views of Responsible Officials: Corrective action was taken. The financial aid team is working in tandem with the Registrar?s Office and the IT department to report enrollment information via the National Student Clearinghouse (NSC). This will be up and running by June 2023, enabling timely reporting of future enrollment status changes to NSLDS.
Federal Program Information: Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Test and Provisions ? Disbursements To or On Behalf of Students - Loan Disbursement Notifications: Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Loan notifications do not appear to have been sent to certain borrowers. Additionally, certain borrowers received inaccurate notifications. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with loan notification requirements. Questioned Costs: None. Context: For 4 of 25 loan disbursement notifications tested, the University did not accurately notify the borrower of the disbursement date, amount, or Direct Loan type. For 2 of 25 Direct Loan disbursements tested, the University was unable to provide documentation showing that a notification was sent to the borrower. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures over loan notifications to ensure timely and accurate notification to borrowers. Views of Responsible Officials: Corrective action was taken. The financial aid team has automated the loan disbursement notification email in JFA to ensure students are notified regarding their loan disbursement amounts, dates, etc. Periodic checks are being done to ensure that the notifications are functioning as expected.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 5 of 9 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: Corrective action was taken. While verification was completed properly for each selected student, when changes were not required to the ISIRs of the students, ISIRs were not consistently released to COD. Now that the University is fully operating with its new financial aid system, JFA, we are running a daily process sending up ISIR corrections to COD for all students. Thorough review and training sessions on the verification process have been held with the financial aid team and we will continue to diligently monitor the verification process, including obtaining necessary documentation from students selected for verification and processing ISIR corrections.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 5 of 9 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: Corrective action was taken. While verification was completed properly for each selected student, when changes were not required to the ISIRs of the students, ISIRs were not consistently released to COD. Now that the University is fully operating with its new financial aid system, JFA, we are running a daily process sending up ISIR corrections to COD for all students. Thorough review and training sessions on the verification process have been held with the financial aid team and we will continue to diligently monitor the verification process, including obtaining necessary documentation from students selected for verification and processing ISIR corrections.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: L. Reporting ? Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the ?ED?) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: Certain student disbursements were not reported to COD within 15 calendar days as required; certain disbursement records did not reflect the actual disbursement date. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the COD reporting requirements. Questioned Costs: None. Context: For 2 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days. For 1 of 25 Pell disbursement records tested, the actual disbursement date was not accurately reported to COD. For 1 of 25 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days. For 1 of 25 Direct Loan disbursement records tested, the actual disbursement date was not accurately reported to COD. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely and accurate reporting to COD. Views of Responsible Officials: Corrective action was taken. The University has since transitioned to a new Financial Aid processing system, Jenzabar Financial Aid (JFA), that automatically sends updates daily, making regular uploads of files to COD much simpler.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 5 of 9 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: Corrective action was taken. While verification was completed properly for each selected student, when changes were not required to the ISIRs of the students, ISIRs were not consistently released to COD. Now that the University is fully operating with its new financial aid system, JFA, we are running a daily process sending up ISIR corrections to COD for all students. Thorough review and training sessions on the verification process have been held with the financial aid team and we will continue to diligently monitor the verification process, including obtaining necessary documentation from students selected for verification and processing ISIR corrections.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code ? The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. Condition: Campus Level: Certain students? enrollment status changes were not reported or were reported outside of the required timeframe. Program Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not certify the student?s enrollment data within 60 days. For 9 of 40 campus level records tested, the University did not notify the Department of the students? enrollment changes. For 12 of 40 campus level records tested, the University did not accurately report the students? enrollment effective dates. For 18 of 25 program level records tested, the University did not accurately report one or more significant data elements to NSLDS. 1 of 6 Enrollment Reporting roster files received during the year was not completed and returned within 15 days. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-002. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students? enrollment statuses are reported accurately and timely to NSLDS. Views of Responsible Officials: Corrective action was taken. The financial aid team is working in tandem with the Registrar?s Office and the IT department to report enrollment information via the National Student Clearinghouse (NSC). This will be up and running by June 2023, enabling timely reporting of future enrollment status changes to NSLDS.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: L. Reporting ? Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the ?ED?) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: Certain student disbursements were not reported to COD within 15 calendar days as required; certain disbursement records did not reflect the actual disbursement date. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the COD reporting requirements. Questioned Costs: None. Context: For 2 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days. For 1 of 25 Pell disbursement records tested, the actual disbursement date was not accurately reported to COD. For 1 of 25 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days. For 1 of 25 Direct Loan disbursement records tested, the actual disbursement date was not accurately reported to COD. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely and accurate reporting to COD. Views of Responsible Officials: Corrective action was taken. The University has since transitioned to a new Financial Aid processing system, Jenzabar Financial Aid (JFA), that automatically sends updates daily, making regular uploads of files to COD much simpler.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 5 of 9 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: Corrective action was taken. While verification was completed properly for each selected student, when changes were not required to the ISIRs of the students, ISIRs were not consistently released to COD. Now that the University is fully operating with its new financial aid system, JFA, we are running a daily process sending up ISIR corrections to COD for all students. Thorough review and training sessions on the verification process have been held with the financial aid team and we will continue to diligently monitor the verification process, including obtaining necessary documentation from students selected for verification and processing ISIR corrections.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code ? The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. Condition: Campus Level: Certain students? enrollment status changes were not reported or were reported outside of the required timeframe. Program Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not certify the student?s enrollment data within 60 days. For 9 of 40 campus level records tested, the University did not notify the Department of the students? enrollment changes. For 12 of 40 campus level records tested, the University did not accurately report the students? enrollment effective dates. For 18 of 25 program level records tested, the University did not accurately report one or more significant data elements to NSLDS. 1 of 6 Enrollment Reporting roster files received during the year was not completed and returned within 15 days. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-002. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students? enrollment statuses are reported accurately and timely to NSLDS. Views of Responsible Officials: Corrective action was taken. The financial aid team is working in tandem with the Registrar?s Office and the IT department to report enrollment information via the National Student Clearinghouse (NSC). This will be up and running by June 2023, enabling timely reporting of future enrollment status changes to NSLDS.
Federal Program Information: Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Test and Provisions ? Disbursements To or On Behalf of Students - Loan Disbursement Notifications: Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Loan notifications do not appear to have been sent to certain borrowers. Additionally, certain borrowers received inaccurate notifications. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with loan notification requirements. Questioned Costs: None. Context: For 4 of 25 loan disbursement notifications tested, the University did not accurately notify the borrower of the disbursement date, amount, or Direct Loan type. For 2 of 25 Direct Loan disbursements tested, the University was unable to provide documentation showing that a notification was sent to the borrower. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures over loan notifications to ensure timely and accurate notification to borrowers. Views of Responsible Officials: Corrective action was taken. The financial aid team has automated the loan disbursement notification email in JFA to ensure students are notified regarding their loan disbursement amounts, dates, etc. Periodic checks are being done to ensure that the notifications are functioning as expected.