Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits.
Condition: During our testing, it was noted the effective date reported on the "Enrollment Level" and "Program Level" report in NSLDS was incorrect for the 4 out of the 20 students tested. In addition, the change in status was reported incorrectly for 1 out of the 20 students.
Questioned Costs: None.
Context: There were discrepancies in the enrollment statuses reported to NSLDS. Also, there were discrepancies between the effective dates reported to NSLDS and the University's records.
Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, 2022-001
Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits.
Condition: During our testing, it was noted the effective date reported on the "Enrollment Level" and "Program Level" report in NSLDS was incorrect for the 4 out of the 20 students tested. In addition, the change in status was reported incorrectly for 1 out of the 20 students.
Questioned Costs: None.
Context: There were discrepancies in the enrollment statuses reported to NSLDS. Also, there were discrepancies between the effective dates reported to NSLDS and the University's records.
Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, 2022-001
Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits.
Condition: During our testing, it was noted the effective date reported on the "Enrollment Level" and "Program Level" report in NSLDS was incorrect for the 4 out of the 20 students tested. In addition, the change in status was reported incorrectly for 1 out of the 20 students.
Questioned Costs: None.
Context: There were discrepancies in the enrollment statuses reported to NSLDS. Also, there were discrepancies between the effective dates reported to NSLDS and the University's records.
Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, 2022-001
Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits.
Condition: During our testing, it was noted the effective date reported on the "Enrollment Level" and "Program Level" report in NSLDS was incorrect for the 4 out of the 20 students tested. In addition, the change in status was reported incorrectly for 1 out of the 20 students.
Questioned Costs: None.
Context: There were discrepancies in the enrollment statuses reported to NSLDS. Also, there were discrepancies between the effective dates reported to NSLDS and the University's records.
Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, 2022-001
Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits.
Condition: During our testing, it was noted the effective date reported on the "Enrollment Level" and "Program Level" report in NSLDS was incorrect for the 4 out of the 20 students tested. In addition, the change in status was reported incorrectly for 1 out of the 20 students.
Questioned Costs: None.
Context: There were discrepancies in the enrollment statuses reported to NSLDS. Also, there were discrepancies between the effective dates reported to NSLDS and the University's records.
Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, 2022-001
Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR
314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP).
Questioned Costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were several elements missing from their WISP.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: Student personal information could be vulnerable.
Repeat Finding: No
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR
314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP).
Questioned Costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were several elements missing from their WISP.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: Student personal information could be vulnerable.
Repeat Finding: No
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR
314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP).
Questioned Costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were several elements missing from their WISP.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: Student personal information could be vulnerable.
Repeat Finding: No
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR
314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP).
Questioned Costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were several elements missing from their WISP.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: Student personal information could be vulnerable.
Repeat Finding: No
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR
314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP).
Questioned Costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were several elements missing from their WISP.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: Student personal information could be vulnerable.
Repeat Finding: No
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing, we noted one check totaling $41.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of August 31, 2023
Questioned Costs: $41.00.
Context: There was one outstanding check for $41.00 related to student refunds of Title IV federal financial aid outstanding more than 240 days.
Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing, we noted one check totaling $41.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of August 31, 2023
Questioned Costs: $41.00.
Context: There was one outstanding check for $41.00 related to student refunds of Title IV federal financial aid outstanding more than 240 days.
Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing, we noted one check totaling $41.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of August 31, 2023
Questioned Costs: $41.00.
Context: There was one outstanding check for $41.00 related to student refunds of Title IV federal financial aid outstanding more than 240 days.
Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing, we noted one check totaling $41.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of August 31, 2023
Questioned Costs: $41.00.
Context: There was one outstanding check for $41.00 related to student refunds of Title IV federal financial aid outstanding more than 240 days.
Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing, we noted one check totaling $41.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of August 31, 2023
Questioned Costs: $41.00.
Context: There was one outstanding check for $41.00 related to student refunds of Title IV federal financial aid outstanding more than 240 days.
Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Perkins Loans
Assistance Listing Number: 84.038
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 674-19(e) states that Institutions must retain original, true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made.
Condition: During our testing, we noted that 5 out of 40 Perkins files tested, the MPN was not retained on file.
Questioned Costs: None.
Context: The MPNs for the five students were not kept for at least three years as required by the regulation.
Cause: The loans were old and as such the records were not able to be found.
Effect: The University was not in compliance with the Perkins recordkeeping regulation as it relates to MPNs.
Repeat Finding: Yes, 2022-003
Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits.
Condition: During our testing, it was noted the effective date reported on the "Enrollment Level" and "Program Level" report in NSLDS was incorrect for the 4 out of the 20 students tested. In addition, the change in status was reported incorrectly for 1 out of the 20 students.
Questioned Costs: None.
Context: There were discrepancies in the enrollment statuses reported to NSLDS. Also, there were discrepancies between the effective dates reported to NSLDS and the University's records.
Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, 2022-001
Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits.
Condition: During our testing, it was noted the effective date reported on the "Enrollment Level" and "Program Level" report in NSLDS was incorrect for the 4 out of the 20 students tested. In addition, the change in status was reported incorrectly for 1 out of the 20 students.
Questioned Costs: None.
Context: There were discrepancies in the enrollment statuses reported to NSLDS. Also, there were discrepancies between the effective dates reported to NSLDS and the University's records.
Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, 2022-001
Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits.
Condition: During our testing, it was noted the effective date reported on the "Enrollment Level" and "Program Level" report in NSLDS was incorrect for the 4 out of the 20 students tested. In addition, the change in status was reported incorrectly for 1 out of the 20 students.
Questioned Costs: None.
Context: There were discrepancies in the enrollment statuses reported to NSLDS. Also, there were discrepancies between the effective dates reported to NSLDS and the University's records.
Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, 2022-001
Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits.
Condition: During our testing, it was noted the effective date reported on the "Enrollment Level" and "Program Level" report in NSLDS was incorrect for the 4 out of the 20 students tested. In addition, the change in status was reported incorrectly for 1 out of the 20 students.
Questioned Costs: None.
Context: There were discrepancies in the enrollment statuses reported to NSLDS. Also, there were discrepancies between the effective dates reported to NSLDS and the University's records.
Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, 2022-001
Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits.
Condition: During our testing, it was noted the effective date reported on the "Enrollment Level" and "Program Level" report in NSLDS was incorrect for the 4 out of the 20 students tested. In addition, the change in status was reported incorrectly for 1 out of the 20 students.
Questioned Costs: None.
Context: There were discrepancies in the enrollment statuses reported to NSLDS. Also, there were discrepancies between the effective dates reported to NSLDS and the University's records.
Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, 2022-001
Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR
314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP).
Questioned Costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were several elements missing from their WISP.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: Student personal information could be vulnerable.
Repeat Finding: No
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR
314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP).
Questioned Costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were several elements missing from their WISP.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: Student personal information could be vulnerable.
Repeat Finding: No
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR
314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP).
Questioned Costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were several elements missing from their WISP.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: Student personal information could be vulnerable.
Repeat Finding: No
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR
314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP).
Questioned Costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were several elements missing from their WISP.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: Student personal information could be vulnerable.
Repeat Finding: No
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR
314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP).
Questioned Costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were several elements missing from their WISP.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: Student personal information could be vulnerable.
Repeat Finding: No
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing, we noted one check totaling $41.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of August 31, 2023
Questioned Costs: $41.00.
Context: There was one outstanding check for $41.00 related to student refunds of Title IV federal financial aid outstanding more than 240 days.
Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing, we noted one check totaling $41.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of August 31, 2023
Questioned Costs: $41.00.
Context: There was one outstanding check for $41.00 related to student refunds of Title IV federal financial aid outstanding more than 240 days.
Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing, we noted one check totaling $41.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of August 31, 2023
Questioned Costs: $41.00.
Context: There was one outstanding check for $41.00 related to student refunds of Title IV federal financial aid outstanding more than 240 days.
Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing, we noted one check totaling $41.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of August 31, 2023
Questioned Costs: $41.00.
Context: There was one outstanding check for $41.00 related to student refunds of Title IV federal financial aid outstanding more than 240 days.
Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing, we noted one check totaling $41.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of August 31, 2023
Questioned Costs: $41.00.
Context: There was one outstanding check for $41.00 related to student refunds of Title IV federal financial aid outstanding more than 240 days.
Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Perkins Loans
Assistance Listing Number: 84.038
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: 2022-2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 674-19(e) states that Institutions must retain original, true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made.
Condition: During our testing, we noted that 5 out of 40 Perkins files tested, the MPN was not retained on file.
Questioned Costs: None.
Context: The MPNs for the five students were not kept for at least three years as required by the regulation.
Cause: The loans were old and as such the records were not able to be found.
Effect: The University was not in compliance with the Perkins recordkeeping regulation as it relates to MPNs.
Repeat Finding: Yes, 2022-003
Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation.
Views of Responsible Officials: There is no disagreement with the audit finding.