2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied.
Condition: During our testing, we noted for 4 out of 80 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication.
Questioned Costs: None reported
Context: The MPNs for the 5 students were not kept for at least three years as required by the regulation.
Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least 3 years after the loan was satisfied.
Effect: The University was not in compliance with the Perkins recordkeeping regulations.
Repeat Finding: No
Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPNs are retained for at least 3 years after payment in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the University on a monthly basis, to reconcile the institutional records with the federal funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted there was no documentation of the reconciliations and reviews of a number of federal funds, including direct loans, Pell, SEOG, TEACH, and Perkins funds.
Questioned Costs: None reported
Context: We noted the proper reviews over reconciliations was not taking place.
Cause: We noted there were not the proper policies and controls in place to make sure this review was occurring.
Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).
Condition: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None reported
Context: We noted that the Organization did not meet the Single Audit compliance requirements over the GLBA Safeguards Rule. Audit procedures required the new Safeguards Rule components to be outlined within the Written Information Security Program and associated policies and procedures. We noted the following areas were not covered in existing, current policies at the University: - Access Controls, - Data Encryption
Cause: The University has not created appropriate policies that address all GLBA Safeguards Rules.
Effect: The University was not in compliance with the GLBA Safeguards Rule regulations.
Repeat Finding: No
Recommendation: We recommend that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls, - Encrypt sensitive information at rest and in transit, and - Dispose of customer information securely and follow appropriate data retention requirements
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
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.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 9 out of 30 students did not have their enrollment status timely reported.
Questioned Costs: None reported
Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester.
Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: No
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: There is no disagreement with the audit finding.
2023-005
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 students tested had a disbursement not reported within the required 15 days.
Questioned Costs: None reported
Context: The disbursement was not reflected in COD until a monthly reconciliation performed outside the fifteen day window.
Cause: The University does not have a process in place to accurate report Direct Loan disbursements to COD within the required 15 days.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be incorrect due to incorrect reporting.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, and Other matter
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need.
Condition: During our testing, we noted for 3 out of 40 students tested an over award over the total cost of attendance totaling $20,993.
Questioned Costs: $20,993
Context: During our testing, it was noted that some other aid amounts were not factored into the calculation of need based aid, resulting in the total aid being over the cost of attendance.
Cause: Management incorrectly calculated federal awards without factoring in all other aid.
Effect: The University is not in compliance with Department of Education Requirements.
Repeat Finding: No
Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.