2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the
student with the status change will be reported on a scheduled transmission within 60 days of the
change in status. Regulations require the status include an accurate effective date. In addition,
regulations require that an institution make necessary corrections and return the records within 10 days
for any roster files that do not pass the NSLDS enrollment reporting edits.
Condition: During our testing, we noted 18 out of the 40 students tested where the student was not
reported in a timely manner after the school determined the students change in status. Furthermore, 3
out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40
students had an incorrect report date reported at the program level.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the student who graduated or
withdrew were reported timely.
Effect: The University did not comply with Department of Education (ED) regulations by reporting
student enrollment status changes timely.
Repeat Finding: Yes – 2022-002
Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure
that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 003 Special Tests: 240 Day Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were
outstanding more than 240 days as of May 31, 2023.
Questioned Costs: $3,074
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of checks refunded to ED after 240 days outstanding.
Cause: The University did not have a process in place to ensure all outstanding checks over 240 days
was properly returned to the ED.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University review its procedures related to
outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the
student with the status change will be reported on a scheduled transmission within 60 days of the
change in status. Regulations require the status include an accurate effective date. In addition,
regulations require that an institution make necessary corrections and return the records within 10 days
for any roster files that do not pass the NSLDS enrollment reporting edits.
Condition: During our testing, we noted 18 out of the 40 students tested where the student was not
reported in a timely manner after the school determined the students change in status. Furthermore, 3
out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40
students had an incorrect report date reported at the program level.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the student who graduated or
withdrew were reported timely.
Effect: The University did not comply with Department of Education (ED) regulations by reporting
student enrollment status changes timely.
Repeat Finding: Yes – 2022-002
Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure
that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 003 Special Tests: 240 Day Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were
outstanding more than 240 days as of May 31, 2023.
Questioned Costs: $3,074
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of checks refunded to ED after 240 days outstanding.
Cause: The University did not have a process in place to ensure all outstanding checks over 240 days
was properly returned to the ED.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University review its procedures related to
outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the
student with the status change will be reported on a scheduled transmission within 60 days of the
change in status. Regulations require the status include an accurate effective date. In addition,
regulations require that an institution make necessary corrections and return the records within 10 days
for any roster files that do not pass the NSLDS enrollment reporting edits.
Condition: During our testing, we noted 18 out of the 40 students tested where the student was not
reported in a timely manner after the school determined the students change in status. Furthermore, 3
out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40
students had an incorrect report date reported at the program level.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the student who graduated or
withdrew were reported timely.
Effect: The University did not comply with Department of Education (ED) regulations by reporting
student enrollment status changes timely.
Repeat Finding: Yes – 2022-002
Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure
that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 003 Special Tests: 240 Day Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were
outstanding more than 240 days as of May 31, 2023.
Questioned Costs: $3,074
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of checks refunded to ED after 240 days outstanding.
Cause: The University did not have a process in place to ensure all outstanding checks over 240 days
was properly returned to the ED.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University review its procedures related to
outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the
student with the status change will be reported on a scheduled transmission within 60 days of the
change in status. Regulations require the status include an accurate effective date. In addition,
regulations require that an institution make necessary corrections and return the records within 10 days
for any roster files that do not pass the NSLDS enrollment reporting edits.
Condition: During our testing, we noted 18 out of the 40 students tested where the student was not
reported in a timely manner after the school determined the students change in status. Furthermore, 3
out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40
students had an incorrect report date reported at the program level.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the student who graduated or
withdrew were reported timely.
Effect: The University did not comply with Department of Education (ED) regulations by reporting
student enrollment status changes timely.
Repeat Finding: Yes – 2022-002
Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure
that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 003 Special Tests: 240 Day Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were
outstanding more than 240 days as of May 31, 2023.
Questioned Costs: $3,074
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of checks refunded to ED after 240 days outstanding.
Cause: The University did not have a process in place to ensure all outstanding checks over 240 days
was properly returned to the ED.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University review its procedures related to
outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the
student with the status change will be reported on a scheduled transmission within 60 days of the
change in status. Regulations require the status include an accurate effective date. In addition,
regulations require that an institution make necessary corrections and return the records within 10 days
for any roster files that do not pass the NSLDS enrollment reporting edits.
Condition: During our testing, we noted 18 out of the 40 students tested where the student was not
reported in a timely manner after the school determined the students change in status. Furthermore, 3
out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40
students had an incorrect report date reported at the program level.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the student who graduated or
withdrew were reported timely.
Effect: The University did not comply with Department of Education (ED) regulations by reporting
student enrollment status changes timely.
Repeat Finding: Yes – 2022-002
Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure
that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 003 Special Tests: 240 Day Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were
outstanding more than 240 days as of May 31, 2023.
Questioned Costs: $3,074
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of checks refunded to ED after 240 days outstanding.
Cause: The University did not have a process in place to ensure all outstanding checks over 240 days
was properly returned to the ED.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University review its procedures related to
outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 004 Perkins Recordkeeping
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.038
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 674-19(e) states that Institutions must retain original, true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made.
Condition: During our testing, we noted that 34 out of the 70 Perkins files tested, the MPN was not retained on file.
Questioned Costs: None
Context: The MPN’s for 34 students were not retained as required by the regulations.
Cause: The loans were old and as such the records were not able to be found.
Effect: The University was not in compliance with the Perkins recordkeeping regulation as it relates to MPNs.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the
student with the status change will be reported on a scheduled transmission within 60 days of the
change in status. Regulations require the status include an accurate effective date. In addition,
regulations require that an institution make necessary corrections and return the records within 10 days
for any roster files that do not pass the NSLDS enrollment reporting edits.
Condition: During our testing, we noted 18 out of the 40 students tested where the student was not
reported in a timely manner after the school determined the students change in status. Furthermore, 3
out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40
students had an incorrect report date reported at the program level.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the student who graduated or
withdrew were reported timely.
Effect: The University did not comply with Department of Education (ED) regulations by reporting
student enrollment status changes timely.
Repeat Finding: Yes – 2022-002
Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure
that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 003 Special Tests: 240 Day Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were
outstanding more than 240 days as of May 31, 2023.
Questioned Costs: $3,074
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of checks refunded to ED after 240 days outstanding.
Cause: The University did not have a process in place to ensure all outstanding checks over 240 days
was properly returned to the ED.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University review its procedures related to
outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the
student with the status change will be reported on a scheduled transmission within 60 days of the
change in status. Regulations require the status include an accurate effective date. In addition,
regulations require that an institution make necessary corrections and return the records within 10 days
for any roster files that do not pass the NSLDS enrollment reporting edits.
Condition: During our testing, we noted 18 out of the 40 students tested where the student was not
reported in a timely manner after the school determined the students change in status. Furthermore, 3
out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40
students had an incorrect report date reported at the program level.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the student who graduated or
withdrew were reported timely.
Effect: The University did not comply with Department of Education (ED) regulations by reporting
student enrollment status changes timely.
Repeat Finding: Yes – 2022-002
Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure
that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 003 Special Tests: 240 Day Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were
outstanding more than 240 days as of May 31, 2023.
Questioned Costs: $3,074
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of checks refunded to ED after 240 days outstanding.
Cause: The University did not have a process in place to ensure all outstanding checks over 240 days
was properly returned to the ED.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University review its procedures related to
outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the
student with the status change will be reported on a scheduled transmission within 60 days of the
change in status. Regulations require the status include an accurate effective date. In addition,
regulations require that an institution make necessary corrections and return the records within 10 days
for any roster files that do not pass the NSLDS enrollment reporting edits.
Condition: During our testing, we noted 18 out of the 40 students tested where the student was not
reported in a timely manner after the school determined the students change in status. Furthermore, 3
out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40
students had an incorrect report date reported at the program level.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the student who graduated or
withdrew were reported timely.
Effect: The University did not comply with Department of Education (ED) regulations by reporting
student enrollment status changes timely.
Repeat Finding: Yes – 2022-002
Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure
that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 003 Special Tests: 240 Day Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were
outstanding more than 240 days as of May 31, 2023.
Questioned Costs: $3,074
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of checks refunded to ED after 240 days outstanding.
Cause: The University did not have a process in place to ensure all outstanding checks over 240 days
was properly returned to the ED.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University review its procedures related to
outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the
student with the status change will be reported on a scheduled transmission within 60 days of the
change in status. Regulations require the status include an accurate effective date. In addition,
regulations require that an institution make necessary corrections and return the records within 10 days
for any roster files that do not pass the NSLDS enrollment reporting edits.
Condition: During our testing, we noted 18 out of the 40 students tested where the student was not
reported in a timely manner after the school determined the students change in status. Furthermore, 3
out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40
students had an incorrect report date reported at the program level.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the student who graduated or
withdrew were reported timely.
Effect: The University did not comply with Department of Education (ED) regulations by reporting
student enrollment status changes timely.
Repeat Finding: Yes – 2022-002
Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure
that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 003 Special Tests: 240 Day Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were
outstanding more than 240 days as of May 31, 2023.
Questioned Costs: $3,074
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of checks refunded to ED after 240 days outstanding.
Cause: The University did not have a process in place to ensure all outstanding checks over 240 days
was properly returned to the ED.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University review its procedures related to
outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the
student with the status change will be reported on a scheduled transmission within 60 days of the
change in status. Regulations require the status include an accurate effective date. In addition,
regulations require that an institution make necessary corrections and return the records within 10 days
for any roster files that do not pass the NSLDS enrollment reporting edits.
Condition: During our testing, we noted 18 out of the 40 students tested where the student was not
reported in a timely manner after the school determined the students change in status. Furthermore, 3
out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40
students had an incorrect report date reported at the program level.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the student who graduated or
withdrew were reported timely.
Effect: The University did not comply with Department of Education (ED) regulations by reporting
student enrollment status changes timely.
Repeat Finding: Yes – 2022-002
Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure
that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 003 Special Tests: 240 Day Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were
outstanding more than 240 days as of May 31, 2023.
Questioned Costs: $3,074
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of checks refunded to ED after 240 days outstanding.
Cause: The University did not have a process in place to ensure all outstanding checks over 240 days
was properly returned to the ED.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University review its procedures related to
outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the
student with the status change will be reported on a scheduled transmission within 60 days of the
change in status. Regulations require the status include an accurate effective date. In addition,
regulations require that an institution make necessary corrections and return the records within 10 days
for any roster files that do not pass the NSLDS enrollment reporting edits.
Condition: During our testing, we noted 18 out of the 40 students tested where the student was not
reported in a timely manner after the school determined the students change in status. Furthermore, 3
out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40
students had an incorrect report date reported at the program level.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the student who graduated or
withdrew were reported timely.
Effect: The University did not comply with Department of Education (ED) regulations by reporting
student enrollment status changes timely.
Repeat Finding: Yes – 2022-002
Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure
that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 003 Special Tests: 240 Day Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were
outstanding more than 240 days as of May 31, 2023.
Questioned Costs: $3,074
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of checks refunded to ED after 240 days outstanding.
Cause: The University did not have a process in place to ensure all outstanding checks over 240 days
was properly returned to the ED.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University review its procedures related to
outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 004 Perkins Recordkeeping
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.038
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 674-19(e) states that Institutions must retain original, true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made.
Condition: During our testing, we noted that 34 out of the 70 Perkins files tested, the MPN was not retained on file.
Questioned Costs: None
Context: The MPN’s for 34 students were not retained as required by the regulations.
Cause: The loans were old and as such the records were not able to be found.
Effect: The University was not in compliance with the Perkins recordkeeping regulation as it relates to MPNs.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the
student with the status change will be reported on a scheduled transmission within 60 days of the
change in status. Regulations require the status include an accurate effective date. In addition,
regulations require that an institution make necessary corrections and return the records within 10 days
for any roster files that do not pass the NSLDS enrollment reporting edits.
Condition: During our testing, we noted 18 out of the 40 students tested where the student was not
reported in a timely manner after the school determined the students change in status. Furthermore, 3
out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40
students had an incorrect report date reported at the program level.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the student who graduated or
withdrew were reported timely.
Effect: The University did not comply with Department of Education (ED) regulations by reporting
student enrollment status changes timely.
Repeat Finding: Yes – 2022-002
Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure
that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.
2023 – 003 Special Tests: 240 Day Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: June 1, 2022 – May 31, 2023
Type of Finding:
-Significant Deficiency in Internal Control over Compliance
-Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states
that an institution that attempts to disburse funds by check and the check is not cashed, the institution
must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were
outstanding more than 240 days as of May 31, 2023.
Questioned Costs: $3,074
Context: During our testing, it was noted the University does not have a process in place to ensure
timeliness and accuracy of checks refunded to ED after 240 days outstanding.
Cause: The University did not have a process in place to ensure all outstanding checks over 240 days
was properly returned to the ED.
Effect: The University is not in compliance with Department of Education requirements that all student
refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the University review its procedures related to
outstanding student refund checks to ensure they are being returned to the Department of Education
after 240 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding.