Federal Agency –Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007; Federal Work Study Program, Assistance Listing Number 84.033; Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Federal Award Program Year – June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determintation that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)).
Condition – The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The University over-returned funds to the Department of Education because of the error in the calculation.
Questioned Costs – None
Context – Of a sample of two return of funds tested from a population of four performed during the examination period, one calculation was not performed correctly. Our sample was not, and was not intended to be, statistically valid.
Cause – The enrollment period was calculated incorrectly.
Effect – The University returned the incorrect amount of funds to the Department of Education.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University be diligent in performing secondary reviews to endure the calculations are performed correctly along with review of inputs into the system to ensure the proper number of days are included in each term.
Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.
Federal Agency –Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007; Federal Work Study Program, Assistance Listing Number 84.033; Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Federal Award Program Year – June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determintation that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)).
Condition – The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The University over-returned funds to the Department of Education because of the error in the calculation.
Questioned Costs – None
Context – Of a sample of two return of funds tested from a population of four performed during the examination period, one calculation was not performed correctly. Our sample was not, and was not intended to be, statistically valid.
Cause – The enrollment period was calculated incorrectly.
Effect – The University returned the incorrect amount of funds to the Department of Education.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University be diligent in performing secondary reviews to endure the calculations are performed correctly along with review of inputs into the system to ensure the proper number of days are included in each term.
Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.
Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Program Year –June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. 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 – The published program date reported to the NSLDS did not match institutional records.
Questioned Costs – None
Context – During our testing, we noted for 21 out of 21 students tested, the published program date reported to the NSLDS does not match the program length per the institution’s records. Our sample was not intended to be statistically valid.
Effect – NSLDS did not contain current and accurate information with respect to published program length.
Identification as a Repeat Finding – Yes, see 2022-003.
Recommendation – We recommend that the University review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting.
Views of Responsible Officials and Planned Corrective Action –
There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Program Year –June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. 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 – The published program date reported to the NSLDS did not match institutional records.
Questioned Costs – None
Context – During our testing, we noted for 21 out of 21 students tested, the published program date reported to the NSLDS does not match the program length per the institution’s records. Our sample was not intended to be statistically valid.
Effect – NSLDS did not contain current and accurate information with respect to published program length.
Identification as a Repeat Finding – Yes, see 2022-003.
Recommendation – We recommend that the University review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting.
Views of Responsible Officials and Planned Corrective Action –
There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.
Federal Agency – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Program Year – June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Borrower Data Transmission – Per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition – During our testing, we noted no documentation of review or completion for the monthly reconciliations for Direct Loans, Pell and SEOG.
Questioned Costs – None
Context – During our testing, it was noted that necessary review and approval to maintain internal controls were not being done.
Cause – Per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Effect – It is possible for errors to occur and not be caught in a timely manner.
Identification as a Repeat Finding – Yes, see 2022-004.
Recommendation –The University has put into place the required reconciliation process. We recommend the University continue this practice.
Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. Corrections for this finding started in January 2023. Initial months selected were prior to that date. Additional months were provided, tested and complied. NCU will continue to do our monthly reconciliations in the same manner.
Federal Agency –Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007; Federal Work Study Program, Assistance Listing Number 84.033; Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Federal Award Program Year – June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determintation that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)).
Condition – The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The University over-returned funds to the Department of Education because of the error in the calculation.
Questioned Costs – None
Context – Of a sample of two return of funds tested from a population of four performed during the examination period, one calculation was not performed correctly. Our sample was not, and was not intended to be, statistically valid.
Cause – The enrollment period was calculated incorrectly.
Effect – The University returned the incorrect amount of funds to the Department of Education.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University be diligent in performing secondary reviews to endure the calculations are performed correctly along with review of inputs into the system to ensure the proper number of days are included in each term.
Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.
Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Program Year –June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. 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 – The published program date reported to the NSLDS did not match institutional records.
Questioned Costs – None
Context – During our testing, we noted for 21 out of 21 students tested, the published program date reported to the NSLDS does not match the program length per the institution’s records. Our sample was not intended to be statistically valid.
Effect – NSLDS did not contain current and accurate information with respect to published program length.
Identification as a Repeat Finding – Yes, see 2022-003.
Recommendation – We recommend that the University review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting.
Views of Responsible Officials and Planned Corrective Action –
There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Program Year –June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. 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 – The published program date reported to the NSLDS did not match institutional records.
Questioned Costs – None
Context – During our testing, we noted for 21 out of 21 students tested, the published program date reported to the NSLDS does not match the program length per the institution’s records. Our sample was not intended to be statistically valid.
Effect – NSLDS did not contain current and accurate information with respect to published program length.
Identification as a Repeat Finding – Yes, see 2022-003.
Recommendation – We recommend that the University review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting.
Views of Responsible Officials and Planned Corrective Action –
There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.
Federal Agency – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Program Year – June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Borrower Data Transmission – Per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition – During our testing, we noted no documentation of review or completion for the monthly reconciliations for Direct Loans, Pell and SEOG.
Questioned Costs – None
Context – During our testing, it was noted that necessary review and approval to maintain internal controls were not being done.
Cause – Per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Effect – It is possible for errors to occur and not be caught in a timely manner.
Identification as a Repeat Finding – Yes, see 2022-004.
Recommendation –The University has put into place the required reconciliation process. We recommend the University continue this practice.
Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. Corrections for this finding started in January 2023. Initial months selected were prior to that date. Additional months were provided, tested and complied. NCU will continue to do our monthly reconciliations in the same manner.
Federal Agency –Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007; Federal Work Study Program, Assistance Listing Number 84.033; Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Federal Award Program Year – June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determintation that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)).
Condition – The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The University over-returned funds to the Department of Education because of the error in the calculation.
Questioned Costs – None
Context – Of a sample of two return of funds tested from a population of four performed during the examination period, one calculation was not performed correctly. Our sample was not, and was not intended to be, statistically valid.
Cause – The enrollment period was calculated incorrectly.
Effect – The University returned the incorrect amount of funds to the Department of Education.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University be diligent in performing secondary reviews to endure the calculations are performed correctly along with review of inputs into the system to ensure the proper number of days are included in each term.
Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.
Federal Agency –Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007; Federal Work Study Program, Assistance Listing Number 84.033; Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Federal Award Program Year – June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determintation that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)).
Condition – The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The University over-returned funds to the Department of Education because of the error in the calculation.
Questioned Costs – None
Context – Of a sample of two return of funds tested from a population of four performed during the examination period, one calculation was not performed correctly. Our sample was not, and was not intended to be, statistically valid.
Cause – The enrollment period was calculated incorrectly.
Effect – The University returned the incorrect amount of funds to the Department of Education.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University be diligent in performing secondary reviews to endure the calculations are performed correctly along with review of inputs into the system to ensure the proper number of days are included in each term.
Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.
Federal Agency –Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007; Federal Work Study Program, Assistance Listing Number 84.033; Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Federal Award Program Year – June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determintation that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)).
Condition – The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The University over-returned funds to the Department of Education because of the error in the calculation.
Questioned Costs – None
Context – Of a sample of two return of funds tested from a population of four performed during the examination period, one calculation was not performed correctly. Our sample was not, and was not intended to be, statistically valid.
Cause – The enrollment period was calculated incorrectly.
Effect – The University returned the incorrect amount of funds to the Department of Education.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University be diligent in performing secondary reviews to endure the calculations are performed correctly along with review of inputs into the system to ensure the proper number of days are included in each term.
Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.
Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Program Year –June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. 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 – The published program date reported to the NSLDS did not match institutional records.
Questioned Costs – None
Context – During our testing, we noted for 21 out of 21 students tested, the published program date reported to the NSLDS does not match the program length per the institution’s records. Our sample was not intended to be statistically valid.
Effect – NSLDS did not contain current and accurate information with respect to published program length.
Identification as a Repeat Finding – Yes, see 2022-003.
Recommendation – We recommend that the University review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting.
Views of Responsible Officials and Planned Corrective Action –
There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Program Year –June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. 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 – The published program date reported to the NSLDS did not match institutional records.
Questioned Costs – None
Context – During our testing, we noted for 21 out of 21 students tested, the published program date reported to the NSLDS does not match the program length per the institution’s records. Our sample was not intended to be statistically valid.
Effect – NSLDS did not contain current and accurate information with respect to published program length.
Identification as a Repeat Finding – Yes, see 2022-003.
Recommendation – We recommend that the University review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting.
Views of Responsible Officials and Planned Corrective Action –
There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.
Federal Agency – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Program Year – June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Borrower Data Transmission – Per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition – During our testing, we noted no documentation of review or completion for the monthly reconciliations for Direct Loans, Pell and SEOG.
Questioned Costs – None
Context – During our testing, it was noted that necessary review and approval to maintain internal controls were not being done.
Cause – Per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Effect – It is possible for errors to occur and not be caught in a timely manner.
Identification as a Repeat Finding – Yes, see 2022-004.
Recommendation –The University has put into place the required reconciliation process. We recommend the University continue this practice.
Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. Corrections for this finding started in January 2023. Initial months selected were prior to that date. Additional months were provided, tested and complied. NCU will continue to do our monthly reconciliations in the same manner.
Federal Agency –Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007; Federal Work Study Program, Assistance Listing Number 84.033; Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Federal Award Program Year – June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determintation that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)).
Condition – The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The University over-returned funds to the Department of Education because of the error in the calculation.
Questioned Costs – None
Context – Of a sample of two return of funds tested from a population of four performed during the examination period, one calculation was not performed correctly. Our sample was not, and was not intended to be, statistically valid.
Cause – The enrollment period was calculated incorrectly.
Effect – The University returned the incorrect amount of funds to the Department of Education.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University be diligent in performing secondary reviews to endure the calculations are performed correctly along with review of inputs into the system to ensure the proper number of days are included in each term.
Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.
Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Program Year –June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. 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 – The published program date reported to the NSLDS did not match institutional records.
Questioned Costs – None
Context – During our testing, we noted for 21 out of 21 students tested, the published program date reported to the NSLDS does not match the program length per the institution’s records. Our sample was not intended to be statistically valid.
Effect – NSLDS did not contain current and accurate information with respect to published program length.
Identification as a Repeat Finding – Yes, see 2022-003.
Recommendation – We recommend that the University review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting.
Views of Responsible Officials and Planned Corrective Action –
There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Program Year –June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. 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 – The published program date reported to the NSLDS did not match institutional records.
Questioned Costs – None
Context – During our testing, we noted for 21 out of 21 students tested, the published program date reported to the NSLDS does not match the program length per the institution’s records. Our sample was not intended to be statistically valid.
Effect – NSLDS did not contain current and accurate information with respect to published program length.
Identification as a Repeat Finding – Yes, see 2022-003.
Recommendation – We recommend that the University review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting.
Views of Responsible Officials and Planned Corrective Action –
There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.
Federal Agency – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Program Year – June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Borrower Data Transmission – Per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition – During our testing, we noted no documentation of review or completion for the monthly reconciliations for Direct Loans, Pell and SEOG.
Questioned Costs – None
Context – During our testing, it was noted that necessary review and approval to maintain internal controls were not being done.
Cause – Per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Effect – It is possible for errors to occur and not be caught in a timely manner.
Identification as a Repeat Finding – Yes, see 2022-004.
Recommendation –The University has put into place the required reconciliation process. We recommend the University continue this practice.
Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. Corrections for this finding started in January 2023. Initial months selected were prior to that date. Additional months were provided, tested and complied. NCU will continue to do our monthly reconciliations in the same manner.
Federal Agency –Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007; Federal Work Study Program, Assistance Listing Number 84.033; Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268.
Federal Award Program Year – June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determintation that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)).
Condition – The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The University over-returned funds to the Department of Education because of the error in the calculation.
Questioned Costs – None
Context – Of a sample of two return of funds tested from a population of four performed during the examination period, one calculation was not performed correctly. Our sample was not, and was not intended to be, statistically valid.
Cause – The enrollment period was calculated incorrectly.
Effect – The University returned the incorrect amount of funds to the Department of Education.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University be diligent in performing secondary reviews to endure the calculations are performed correctly along with review of inputs into the system to ensure the proper number of days are included in each term.
Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.