Audit 293420

Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: In a sample of 7 students that withdrew during the fiscal year, the University calculated the required return to Title IV for one student incorrectly by using the incorrect number of days for the base. The sample was not a statistically valid sample. Cause: The University incorrectly used the wrong number of days as a base for the spring semester to use in the return of Title IV funds calculation. Effect: The return of Title IV (R2T4) funds calculations were incorrect for the Spring 2023 term requiring the student to return more than required. Questioned costs: The error resulted in $43 more in Direct Student Loan funds returned than required. Recommendation: It is recommended that the University review interpretations, policies and procedures in place for withdrawals and R2T4 calculations to ensure that correct dates and institutional charges are being used. Management Response: The Financial Aid office reviewed documentation to determine the total number of students impacted by this finding. No corrections to other students are required. This finding was reviewed and discussed with Financial Aid staff, including training, to review correct calculations for future semester/term calendar days. The University also reviewed days uses for 2023-2024 calendar to ensure they are in line with regulations.

Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: For one out of a sample of 25 students, the effective date reported to NSLDS for a withdrawn student was the date of determination rather than the last date of attendance. The sample was not a statistically valid sample. Cause: The University failed to follow its procedures for reporting student status changes correctly and/or within the required timeframe. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned costs: Not applicable. Context: Not applicable. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct program level effective dates and enrollment statuses are reported to the NSLDS within the required timeframes after the information has been submitted through the servicer (National Student Clearinghouse). This could include a review of withdrawal or graduation dates compared to the effective dates and enrollment statuses reported to the NSLDS to make sure they are accurate. Management Response: For the one student found to have the incorrect date reported, the University is conducting additional training in the registrar’s office and will continue to focus on improving procedures to ensure the correct date is reported.

Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: In a sample of 7 students that withdrew during the fiscal year, the University calculated the required return to Title IV for one student incorrectly by using the incorrect number of days for the base. The sample was not a statistically valid sample. Cause: The University incorrectly used the wrong number of days as a base for the spring semester to use in the return of Title IV funds calculation. Effect: The return of Title IV (R2T4) funds calculations were incorrect for the Spring 2023 term requiring the student to return more than required. Questioned costs: The error resulted in $43 more in Direct Student Loan funds returned than required. Recommendation: It is recommended that the University review interpretations, policies and procedures in place for withdrawals and R2T4 calculations to ensure that correct dates and institutional charges are being used. Management Response: The Financial Aid office reviewed documentation to determine the total number of students impacted by this finding. No corrections to other students are required. This finding was reviewed and discussed with Financial Aid staff, including training, to review correct calculations for future semester/term calendar days. The University also reviewed days uses for 2023-2024 calendar to ensure they are in line with regulations.

Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: For one out of a sample of 25 students, the effective date reported to NSLDS for a withdrawn student was the date of determination rather than the last date of attendance. The sample was not a statistically valid sample. Cause: The University failed to follow its procedures for reporting student status changes correctly and/or within the required timeframe. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned costs: Not applicable. Context: Not applicable. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct program level effective dates and enrollment statuses are reported to the NSLDS within the required timeframes after the information has been submitted through the servicer (National Student Clearinghouse). This could include a review of withdrawal or graduation dates compared to the effective dates and enrollment statuses reported to the NSLDS to make sure they are accurate. Management Response: For the one student found to have the incorrect date reported, the University is conducting additional training in the registrar’s office and will continue to focus on improving procedures to ensure the correct date is reported.