Audit 292453

Criteria: Title IV regulations (34 CFR 668.164(h)(1) require that Title IV credit balances on student accounts be paid directly to the student as soon as possible but no later than 14 days after the balance occurred. A student or parent may authorize the Institution to hold the credit balance to be applied to specified other nontuition fees, room and board charges, up to $200 of prior year, or future charges as noted in the regulations at (34 CFR 668.165(b)). Condition/Context: For 4 of 25 students tested, the students’ Title IV credit balances on their accounts were held and applied to future charges without student or parent authorization. The sample was not a statistically valid sample. Cause: The University's controls surrounding Title IV credit balances being paid timely or being held only when authorized by the student/parent did not detect or appropriately handle the Title IV credit balances. Effect: Title IV credit balances were held without student/parent authorization and applied to future charges. Questioned Costs: Total questioned costs were $18,947 of Federal Direct Student Loan funds ALN 84.268. Recommendation: The University should revise its procedures to ensure Title IV credit balances are paid timely or student/parent authorizations to hold funds are obtained. Management's Response: The University agrees with the finding. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review is being conducted of current internal control processes and evaluating what additional reporting is capable within the student information system to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances are being monitored during the Spring 2023 terms and new procedures will be put in place for the Fall 2024 term.

Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, and the student has ceased to be enrolled on at least a halftime 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 institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The following exceptions were noted in our testing:  Two students' graduate dates reported to NSLDS did not agree to the support provided from the University's system. The University subsequently corrected these students’ records in NSLDS and the auditor viewed the screen prints with the corrections.  One student was originally reported as half time to NSLDS and later changed full time and then back to half time. The full-time status was never reported NSLDS. The University subsequently corrected the student’s record in NSLDS and the auditor viewed the screen print with the corrections.  One student's change from full time to less than half time status was incorrectly not reported to NSLDS when they added a summer class during the summer of 2022. The University subsequently corrected the student’s record in NSLDS and the auditor viewed the screen prints with the corrections.  Two students with changes from full time to less than half time for the summer of 2023 were reported to the clearinghouse, but the notification in NSLDS does not show that the status was reflected within NSLDS program level or campus level reporting. The University provided screenshots showing that the enrollment history was updated in NSLDS for the two students.  One student with changes from full time to less than half time for the summer of 2023 were reported to the clearinghouse, but the notification in NSLDS does not show that the status was reflected within NSLDS campus level reporting. The status change does show up in the program level reporting. The University provided screenshots showing that the enrollment history was updated in NSLDS for the student. The sample was not a statistically valid sample. Cause: The University's controls surrounding NSLDS enrollment reporting did not detect or appropriately handle errors and omissions in the reporting. Effect: Incorrect information was reported to NSLDS and a student was also omitted from reporting. Questioned Costs: Not applicable. Recommendation: The University should revise its procedures to ensure NSLDS enrollment reporting is completed accurately and timely for all status changes and all students. Management's Response: The University has made all corrections to the identified records. The University is reviewing its current processes and evaluating if additional review controls need to be put in place to ensure timely and accurate NSLDS data.

Criteria: Title IV regulations (34 CFR 668.164(h)(1) require that Title IV credit balances on student accounts be paid directly to the student as soon as possible but no later than 14 days after the balance occurred. A student or parent may authorize the Institution to hold the credit balance to be applied to specified other nontuition fees, room and board charges, up to $200 of prior year, or future charges as noted in the regulations at (34 CFR 668.165(b)). Condition/Context: For 4 of 25 students tested, the students’ Title IV credit balances on their accounts were held and applied to future charges without student or parent authorization. The sample was not a statistically valid sample. Cause: The University's controls surrounding Title IV credit balances being paid timely or being held only when authorized by the student/parent did not detect or appropriately handle the Title IV credit balances. Effect: Title IV credit balances were held without student/parent authorization and applied to future charges. Questioned Costs: Total questioned costs were $18,947 of Federal Direct Student Loan funds ALN 84.268. Recommendation: The University should revise its procedures to ensure Title IV credit balances are paid timely or student/parent authorizations to hold funds are obtained. Management's Response: The University agrees with the finding. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review is being conducted of current internal control processes and evaluating what additional reporting is capable within the student information system to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances are being monitored during the Spring 2023 terms and new procedures will be put in place for the Fall 2024 term.

Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, and the student has ceased to be enrolled on at least a halftime 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 institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The following exceptions were noted in our testing:  Two students' graduate dates reported to NSLDS did not agree to the support provided from the University's system. The University subsequently corrected these students’ records in NSLDS and the auditor viewed the screen prints with the corrections.  One student was originally reported as half time to NSLDS and later changed full time and then back to half time. The full-time status was never reported NSLDS. The University subsequently corrected the student’s record in NSLDS and the auditor viewed the screen print with the corrections.  One student's change from full time to less than half time status was incorrectly not reported to NSLDS when they added a summer class during the summer of 2022. The University subsequently corrected the student’s record in NSLDS and the auditor viewed the screen prints with the corrections.  Two students with changes from full time to less than half time for the summer of 2023 were reported to the clearinghouse, but the notification in NSLDS does not show that the status was reflected within NSLDS program level or campus level reporting. The University provided screenshots showing that the enrollment history was updated in NSLDS for the two students.  One student with changes from full time to less than half time for the summer of 2023 were reported to the clearinghouse, but the notification in NSLDS does not show that the status was reflected within NSLDS campus level reporting. The status change does show up in the program level reporting. The University provided screenshots showing that the enrollment history was updated in NSLDS for the student. The sample was not a statistically valid sample. Cause: The University's controls surrounding NSLDS enrollment reporting did not detect or appropriately handle errors and omissions in the reporting. Effect: Incorrect information was reported to NSLDS and a student was also omitted from reporting. Questioned Costs: Not applicable. Recommendation: The University should revise its procedures to ensure NSLDS enrollment reporting is completed accurately and timely for all status changes and all students. Management's Response: The University has made all corrections to the identified records. The University is reviewing its current processes and evaluating if additional review controls need to be put in place to ensure timely and accurate NSLDS data.