Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts.
Condition: During our testing of disbursements to eligible students, we noted one instance of a Pell award not being properly disbursed.
Questioned costs: None reported.
Context: In our eligibility sample of 40, one student was not properly disbursed their Pell award. Student was enrolled half-time for fall and winter, and less-than-half time for spring. Student only received a disbursement in fall.
Cause: The students award was based on full-time enrollment level, but the student was only enrolled half-time in fall and winter. Pell recalculation was not performed for this student, and remaining aid was not paid.
Effect: A student did not receive all their Pell Grant Aid.
Repeat Finding: No.
Recommendation: We recommend the University review the current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our enrollment reporting testing, we noted the University did not update student enrollment data correctly or timely.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment status for 2 of the 40 students tested. The enrollment effective date of 6 of the 40 students tested was not reported correctly to NSLDS. The status change of 28 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 40 students tested. The program enrollment effective date of 3 of 40 students tested did not match the institutions records. The program enrollment status of 2 of 40 students tested did not match the status per the institution.
Cause: The University did accurately report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Additionally, NSC did not report all status changes timely which caused the University to not meet the requirements.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: No.
Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our enrollment reporting testing, we noted the University did not update student enrollment data correctly or timely.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment status for 2 of the 40 students tested. The enrollment effective date of 6 of the 40 students tested was not reported correctly to NSLDS. The status change of 28 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 40 students tested. The program enrollment effective date of 3 of 40 students tested did not match the institutions records. The program enrollment status of 2 of 40 students tested did not match the status per the institution.
Cause: The University did accurately report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Additionally, NSC did not report all status changes timely which caused the University to not meet the requirements.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: No.
Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our enrollment reporting testing, we noted the University did not update student enrollment data correctly or timely.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment status for 2 of the 40 students tested. The enrollment effective date of 6 of the 40 students tested was not reported correctly to NSLDS. The status change of 28 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 40 students tested. The program enrollment effective date of 3 of 40 students tested did not match the institutions records. The program enrollment status of 2 of 40 students tested did not match the status per the institution.
Cause: The University did accurately report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Additionally, NSC did not report all status changes timely which caused the University to not meet the requirements.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: No.
Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our enrollment reporting testing, we noted the University did not update student enrollment data correctly or timely.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment status for 2 of the 40 students tested. The enrollment effective date of 6 of the 40 students tested was not reported correctly to NSLDS. The status change of 28 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 40 students tested. The program enrollment effective date of 3 of 40 students tested did not match the institutions records. The program enrollment status of 2 of 40 students tested did not match the status per the institution.
Cause: The University did accurately report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Additionally, NSC did not report all status changes timely which caused the University to not meet the requirements.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: No.
Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our enrollment reporting testing, we noted the University did not update student enrollment data correctly or timely.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment status for 2 of the 40 students tested. The enrollment effective date of 6 of the 40 students tested was not reported correctly to NSLDS. The status change of 28 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 40 students tested. The program enrollment effective date of 3 of 40 students tested did not match the institutions records. The program enrollment status of 2 of 40 students tested did not match the status per the institution.
Cause: The University did accurately report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Additionally, NSC did not report all status changes timely which caused the University to not meet the requirements.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: No.
Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: Under section 2003(5) of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient must use a portion of their institutional funds received under this supplemental award to (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as amended (HEA) (20 USC § 1087tt). In addition, Uniform Grant Guidance (2 CFR 20.303) requires nonfederal entities receiving Federal awards establish and maintain controls designed to reasonable ensure compliance with Federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted there was no amount allocated to the earmarking requirement.
Questioned costs: None reported.
Context: During our testing, we noted the University was not in compliance with the annual reporting requirements because the University did not report ARP funds expended to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student or other circumstances, described in section 479A of the HEA.
Cause: The policies and procedures of the University did not ensure that annual reporting requirements to report amounts spent for earmarking requirements were accurately met.
Effect: The University inaccurately reported the amount spent under earmarking requirements. Non-compliance with federal regulations could lead to funds being required to be returned or refunded in order to meet the reporting requirement.
Repeat Finding: No.
Recommendation: We recommend the University revise their report to properly show the amount spent under earmarking requirements. In addition, we recommend the University put procedures in place to review earmarking requirements and properly track them for reporting purposes.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts.
Condition: During our testing of disbursements to eligible students, we noted one instance of a Pell award not being properly disbursed.
Questioned costs: None reported.
Context: In our eligibility sample of 40, one student was not properly disbursed their Pell award. Student was enrolled half-time for fall and winter, and less-than-half time for spring. Student only received a disbursement in fall.
Cause: The students award was based on full-time enrollment level, but the student was only enrolled half-time in fall and winter. Pell recalculation was not performed for this student, and remaining aid was not paid.
Effect: A student did not receive all their Pell Grant Aid.
Repeat Finding: No.
Recommendation: We recommend the University review the current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our enrollment reporting testing, we noted the University did not update student enrollment data correctly or timely.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment status for 2 of the 40 students tested. The enrollment effective date of 6 of the 40 students tested was not reported correctly to NSLDS. The status change of 28 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 40 students tested. The program enrollment effective date of 3 of 40 students tested did not match the institutions records. The program enrollment status of 2 of 40 students tested did not match the status per the institution.
Cause: The University did accurately report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Additionally, NSC did not report all status changes timely which caused the University to not meet the requirements.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: No.
Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our enrollment reporting testing, we noted the University did not update student enrollment data correctly or timely.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment status for 2 of the 40 students tested. The enrollment effective date of 6 of the 40 students tested was not reported correctly to NSLDS. The status change of 28 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 40 students tested. The program enrollment effective date of 3 of 40 students tested did not match the institutions records. The program enrollment status of 2 of 40 students tested did not match the status per the institution.
Cause: The University did accurately report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Additionally, NSC did not report all status changes timely which caused the University to not meet the requirements.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: No.
Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our enrollment reporting testing, we noted the University did not update student enrollment data correctly or timely.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment status for 2 of the 40 students tested. The enrollment effective date of 6 of the 40 students tested was not reported correctly to NSLDS. The status change of 28 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 40 students tested. The program enrollment effective date of 3 of 40 students tested did not match the institutions records. The program enrollment status of 2 of 40 students tested did not match the status per the institution.
Cause: The University did accurately report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Additionally, NSC did not report all status changes timely which caused the University to not meet the requirements.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: No.
Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our enrollment reporting testing, we noted the University did not update student enrollment data correctly or timely.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment status for 2 of the 40 students tested. The enrollment effective date of 6 of the 40 students tested was not reported correctly to NSLDS. The status change of 28 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 40 students tested. The program enrollment effective date of 3 of 40 students tested did not match the institutions records. The program enrollment status of 2 of 40 students tested did not match the status per the institution.
Cause: The University did accurately report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Additionally, NSC did not report all status changes timely which caused the University to not meet the requirements.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: No.
Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our enrollment reporting testing, we noted the University did not update student enrollment data correctly or timely.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment status for 2 of the 40 students tested. The enrollment effective date of 6 of the 40 students tested was not reported correctly to NSLDS. The status change of 28 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 40 students tested. The program enrollment effective date of 3 of 40 students tested did not match the institutions records. The program enrollment status of 2 of 40 students tested did not match the status per the institution.
Cause: The University did accurately report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Additionally, NSC did not report all status changes timely which caused the University to not meet the requirements.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: No.
Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: Under section 2003(5) of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient must use a portion of their institutional funds received under this supplemental award to (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as amended (HEA) (20 USC § 1087tt). In addition, Uniform Grant Guidance (2 CFR 20.303) requires nonfederal entities receiving Federal awards establish and maintain controls designed to reasonable ensure compliance with Federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted there was no amount allocated to the earmarking requirement.
Questioned costs: None reported.
Context: During our testing, we noted the University was not in compliance with the annual reporting requirements because the University did not report ARP funds expended to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student or other circumstances, described in section 479A of the HEA.
Cause: The policies and procedures of the University did not ensure that annual reporting requirements to report amounts spent for earmarking requirements were accurately met.
Effect: The University inaccurately reported the amount spent under earmarking requirements. Non-compliance with federal regulations could lead to funds being required to be returned or refunded in order to meet the reporting requirement.
Repeat Finding: No.
Recommendation: We recommend the University revise their report to properly show the amount spent under earmarking requirements. In addition, we recommend the University put procedures in place to review earmarking requirements and properly track them for reporting purposes.
View of Responsible Official: The University agrees with the finding.