Common Origination and Disbursement (COD) Reporting Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The dates when Federal Direct Loans (FDL) and Pell were disbursed to student's account did not always agree to the disbursement dates as reported in COD.
Criteria: 34CFR 668.164(a)
Questioned Costs: $0
Context: Out of 259 subsidized, unsubsidized, Plus loans, and Pell disbursement records tested, 25 had COD loan and Pell disbursement date errors. The errors were primarily a spring 2023 disbursement batch which reported Pell and FDL disbursements to COD as 2/21/2023 but were actually posted to the students’ accounts on 3/24/2023. There were no errors in the amounts reported, just the date of disbursement and the funds were not drawn down from G5 until 3/28/2023 so no cash management violation noted.
Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students' accounts.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The dates when Federal Direct Loans (FDL) and Pell were disbursed to student's account did not always agree to the disbursement dates as reported in COD.
Criteria: 34CFR 668.164(a)
Questioned Costs: $0
Context: Out of 259 subsidized, unsubsidized, Plus loans, and Pell disbursement records tested, 25 had COD loan and Pell disbursement date errors. The errors were primarily a spring 2023 disbursement batch which reported Pell and FDL disbursements to COD as 2/21/2023 but were actually posted to the students’ accounts on 3/24/2023. There were no errors in the amounts reported, just the date of disbursement and the funds were not drawn down from G5 until 3/28/2023 so no cash management violation noted.
Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students' accounts.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Untimely Returns of Title IV Funds (R2T4)Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Award Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $0
Context: Out of 8 students, 3 students who withdrew during the audit period tested had a total of $7,790 funds returned late ranging from 35 to 83 days. For 1 of these students, the University originally had incorrectly returned all of the student’s Pell but no FDL so the net funds returned late were $594. 2 of these students had a total of $983 more in FDL returned than the required.
Cause: Staffing challenges. Delays in processing R2T4’s even though the calculations were completed timely. While the calculations were completed correctly, the actual amounts returned included the funds that both the school and student were responsible for returning to the Department of Education.
Effect: Returns of Title IV funds were not performed timely.
Identification as repeat finding, if applicable: Yes, 2022-001
Recommendation: We recommend that additional training be completed on R2T4 processing. We also recommend that financial aid office work with the registrar to put procedures in place for timely notification when students stop attending and that financial aid process the R2T4’s timely when required.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Untimely Returns of Title IV Funds (R2T4)Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Award Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $0
Context: Out of 8 students, 3 students who withdrew during the audit period tested had a total of $7,790 funds returned late ranging from 35 to 83 days. For 1 of these students, the University originally had incorrectly returned all of the student’s Pell but no FDL so the net funds returned late were $594. 2 of these students had a total of $983 more in FDL returned than the required.
Cause: Staffing challenges. Delays in processing R2T4’s even though the calculations were completed timely. While the calculations were completed correctly, the actual amounts returned included the funds that both the school and student were responsible for returning to the Department of Education.
Effect: Returns of Title IV funds were not performed timely.
Identification as repeat finding, if applicable: Yes, 2022-001
Recommendation: We recommend that additional training be completed on R2T4 processing. We also recommend that financial aid office work with the registrar to put procedures in place for timely notification when students stop attending and that financial aid process the R2T4’s timely when required.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not:
- implemented multi-factor authentication on one vendor system containing personally identifiable information (PII) - implemented sufficient vendor management policies and reviews - provided a written, annual report to the board
We noted the University has been evaluating vendors, and the criteria for evaluating vendors is being revised to incorporate the updated regulations of GLBA. Additionally, while information related to the information security program has been shared with the board, a more robust written report will be implemented. We commend the University for the work completed related to GLBA.
Cause: The University has not formalized all documentation of processes and upcoming revised vendor management processes to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University formalize and document processes to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not:
- implemented multi-factor authentication on one vendor system containing personally identifiable information (PII) - implemented sufficient vendor management policies and reviews - provided a written, annual report to the board
We noted the University has been evaluating vendors, and the criteria for evaluating vendors is being revised to incorporate the updated regulations of GLBA. Additionally, while information related to the information security program has been shared with the board, a more robust written report will be implemented. We commend the University for the work completed related to GLBA.
Cause: The University has not formalized all documentation of processes and upcoming revised vendor management processes to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University formalize and document processes to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not:
- implemented multi-factor authentication on one vendor system containing personally identifiable information (PII) - implemented sufficient vendor management policies and reviews - provided a written, annual report to the board
We noted the University has been evaluating vendors, and the criteria for evaluating vendors is being revised to incorporate the updated regulations of GLBA. Additionally, while information related to the information security program has been shared with the board, a more robust written report will be implemented. We commend the University for the work completed related to GLBA.
Cause: The University has not formalized all documentation of processes and upcoming revised vendor management processes to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University formalize and document processes to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not:
- implemented multi-factor authentication on one vendor system containing personally identifiable information (PII) - implemented sufficient vendor management policies and reviews - provided a written, annual report to the board
We noted the University has been evaluating vendors, and the criteria for evaluating vendors is being revised to incorporate the updated regulations of GLBA. Additionally, while information related to the information security program has been shared with the board, a more robust written report will be implemented. We commend the University for the work completed related to GLBA.
Cause: The University has not formalized all documentation of processes and upcoming revised vendor management processes to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University formalize and document processes to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Pell Awards DEPARTMENT OF EDUCATION
ALN #: 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: Students were not always properly awarded Pell based on enrollment status.
Criteria: 34 CFR 690.63(b)
Questioned Costs: $0
Context: Out of 33 students tested, 1 student was eligible for Pell of $1,724 in the spring term but was not awarded due to an error in the auto packaging calculation in the system. This was corrected during the audit. 1 student had not used their full annual Pell eligibility and was under awarded Pell by $618 for the summer term.
Cause: Incorrect system setup in Regent
Effect: Pell was not awarded correctly based on enrollment status.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend a process be used to review system setups to adjust Pell to be paid in alignment with enrollment status.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The dates when Federal Direct Loans (FDL) and Pell were disbursed to student's account did not always agree to the disbursement dates as reported in COD.
Criteria: 34CFR 668.164(a)
Questioned Costs: $0
Context: Out of 259 subsidized, unsubsidized, Plus loans, and Pell disbursement records tested, 25 had COD loan and Pell disbursement date errors. The errors were primarily a spring 2023 disbursement batch which reported Pell and FDL disbursements to COD as 2/21/2023 but were actually posted to the students’ accounts on 3/24/2023. There were no errors in the amounts reported, just the date of disbursement and the funds were not drawn down from G5 until 3/28/2023 so no cash management violation noted.
Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students' accounts.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The dates when Federal Direct Loans (FDL) and Pell were disbursed to student's account did not always agree to the disbursement dates as reported in COD.
Criteria: 34CFR 668.164(a)
Questioned Costs: $0
Context: Out of 259 subsidized, unsubsidized, Plus loans, and Pell disbursement records tested, 25 had COD loan and Pell disbursement date errors. The errors were primarily a spring 2023 disbursement batch which reported Pell and FDL disbursements to COD as 2/21/2023 but were actually posted to the students’ accounts on 3/24/2023. There were no errors in the amounts reported, just the date of disbursement and the funds were not drawn down from G5 until 3/28/2023 so no cash management violation noted.
Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students' accounts.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Untimely Returns of Title IV Funds (R2T4)Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Award Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $0
Context: Out of 8 students, 3 students who withdrew during the audit period tested had a total of $7,790 funds returned late ranging from 35 to 83 days. For 1 of these students, the University originally had incorrectly returned all of the student’s Pell but no FDL so the net funds returned late were $594. 2 of these students had a total of $983 more in FDL returned than the required.
Cause: Staffing challenges. Delays in processing R2T4’s even though the calculations were completed timely. While the calculations were completed correctly, the actual amounts returned included the funds that both the school and student were responsible for returning to the Department of Education.
Effect: Returns of Title IV funds were not performed timely.
Identification as repeat finding, if applicable: Yes, 2022-001
Recommendation: We recommend that additional training be completed on R2T4 processing. We also recommend that financial aid office work with the registrar to put procedures in place for timely notification when students stop attending and that financial aid process the R2T4’s timely when required.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Untimely Returns of Title IV Funds (R2T4)Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Award Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $0
Context: Out of 8 students, 3 students who withdrew during the audit period tested had a total of $7,790 funds returned late ranging from 35 to 83 days. For 1 of these students, the University originally had incorrectly returned all of the student’s Pell but no FDL so the net funds returned late were $594. 2 of these students had a total of $983 more in FDL returned than the required.
Cause: Staffing challenges. Delays in processing R2T4’s even though the calculations were completed timely. While the calculations were completed correctly, the actual amounts returned included the funds that both the school and student were responsible for returning to the Department of Education.
Effect: Returns of Title IV funds were not performed timely.
Identification as repeat finding, if applicable: Yes, 2022-001
Recommendation: We recommend that additional training be completed on R2T4 processing. We also recommend that financial aid office work with the registrar to put procedures in place for timely notification when students stop attending and that financial aid process the R2T4’s timely when required.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not:
- implemented multi-factor authentication on one vendor system containing personally identifiable information (PII) - implemented sufficient vendor management policies and reviews - provided a written, annual report to the board
We noted the University has been evaluating vendors, and the criteria for evaluating vendors is being revised to incorporate the updated regulations of GLBA. Additionally, while information related to the information security program has been shared with the board, a more robust written report will be implemented. We commend the University for the work completed related to GLBA.
Cause: The University has not formalized all documentation of processes and upcoming revised vendor management processes to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University formalize and document processes to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not:
- implemented multi-factor authentication on one vendor system containing personally identifiable information (PII) - implemented sufficient vendor management policies and reviews - provided a written, annual report to the board
We noted the University has been evaluating vendors, and the criteria for evaluating vendors is being revised to incorporate the updated regulations of GLBA. Additionally, while information related to the information security program has been shared with the board, a more robust written report will be implemented. We commend the University for the work completed related to GLBA.
Cause: The University has not formalized all documentation of processes and upcoming revised vendor management processes to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University formalize and document processes to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not:
- implemented multi-factor authentication on one vendor system containing personally identifiable information (PII) - implemented sufficient vendor management policies and reviews - provided a written, annual report to the board
We noted the University has been evaluating vendors, and the criteria for evaluating vendors is being revised to incorporate the updated regulations of GLBA. Additionally, while information related to the information security program has been shared with the board, a more robust written report will be implemented. We commend the University for the work completed related to GLBA.
Cause: The University has not formalized all documentation of processes and upcoming revised vendor management processes to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University formalize and document processes to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not:
- implemented multi-factor authentication on one vendor system containing personally identifiable information (PII) - implemented sufficient vendor management policies and reviews - provided a written, annual report to the board
We noted the University has been evaluating vendors, and the criteria for evaluating vendors is being revised to incorporate the updated regulations of GLBA. Additionally, while information related to the information security program has been shared with the board, a more robust written report will be implemented. We commend the University for the work completed related to GLBA.
Cause: The University has not formalized all documentation of processes and upcoming revised vendor management processes to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University formalize and document processes to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Pell Awards DEPARTMENT OF EDUCATION
ALN #: 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: Students were not always properly awarded Pell based on enrollment status.
Criteria: 34 CFR 690.63(b)
Questioned Costs: $0
Context: Out of 33 students tested, 1 student was eligible for Pell of $1,724 in the spring term but was not awarded due to an error in the auto packaging calculation in the system. This was corrected during the audit. 1 student had not used their full annual Pell eligibility and was under awarded Pell by $618 for the summer term.
Cause: Incorrect system setup in Regent
Effect: Pell was not awarded correctly based on enrollment status.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend a process be used to review system setups to adjust Pell to be paid in alignment with enrollment status.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.