Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: During testing of cash management, there was no approval support for 2 of 6 Title IV drawdowns selected for testing.
Questioned Costs: None
Context: During our testing cash management, the University was unable to locate documented approval for 2 of 6 drawdown selections.
Cause: There was turnover throughout the year and a paper trail was not always maintained.
Effect: Documentation was not maintained to support the review and approval of drawdowns made by management.
Repeat Finding: No.
Recommendation: We recommend that the University ensure proper evidence of approval is maintained for all Title IV drawdowns.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: During testing of cash management, there was no approval support for 2 of 6 Title IV drawdowns selected for testing.
Questioned Costs: None
Context: During our testing cash management, the University was unable to locate documented approval for 2 of 6 drawdown selections.
Cause: There was turnover throughout the year and a paper trail was not always maintained.
Effect: Documentation was not maintained to support the review and approval of drawdowns made by management.
Repeat Finding: No.
Recommendation: We recommend that the University ensure proper evidence of approval is maintained for all Title IV drawdowns.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: During testing of cash management, there was no approval support for 2 of 6 Title IV drawdowns selected for testing.
Questioned Costs: None
Context: During our testing cash management, the University was unable to locate documented approval for 2 of 6 drawdown selections.
Cause: There was turnover throughout the year and a paper trail was not always maintained.
Effect: Documentation was not maintained to support the review and approval of drawdowns made by management.
Repeat Finding: No.
Recommendation: We recommend that the University ensure proper evidence of approval is maintained for all Title IV drawdowns.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: During testing of cash management, there was no approval support for 2 of 6 Title IV drawdowns selected for testing.
Questioned Costs: None
Context: During our testing cash management, the University was unable to locate documented approval for 2 of 6 drawdown selections.
Cause: There was turnover throughout the year and a paper trail was not always maintained.
Effect: Documentation was not maintained to support the review and approval of drawdowns made by management.
Repeat Finding: No.
Recommendation: We recommend that the University ensure proper evidence of approval is maintained for all Title IV drawdowns.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: During testing of cash management, there was no approval support for 2 of 6 Title IV drawdowns selected for testing.
Questioned Costs: None
Context: During our testing cash management, the University was unable to locate documented approval for 2 of 6 drawdown selections.
Cause: There was turnover throughout the year and a paper trail was not always maintained.
Effect: Documentation was not maintained to support the review and approval of drawdowns made by management.
Repeat Finding: No.
Recommendation: We recommend that the University ensure proper evidence of approval is maintained for all Title IV drawdowns.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: During testing of cash management, there was no approval support for 2 of 6 Title IV drawdowns selected for testing.
Questioned Costs: None
Context: During our testing cash management, the University was unable to locate documented approval for 2 of 6 drawdown selections.
Cause: There was turnover throughout the year and a paper trail was not always maintained.
Effect: Documentation was not maintained to support the review and approval of drawdowns made by management.
Repeat Finding: No.
Recommendation: We recommend that the University ensure proper evidence of approval is maintained for all Title IV drawdowns.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires an institution to reconcile their records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary monthly.
Condition: Direct loan reconciliations between the COD, G5 and student accounts were not being documented as performed during the year.
Questioned Costs: None
Context: While testing direct loan reconciliations, it was noted that the University was reconciling direct loan activity nearly daily. However, the University did not maintain supporting documentation that the reconciliation process took place.
Cause: There was turnover at the University during the year and not all documentation was maintained or could be located.
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. There should be a process to maintain all reconciliations to support these were performed as required monthly.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures.
Condition: During our testing, it was noted 3 of 8 students did not have the required support in their student files.
Questioned Costs: None
Context: During our testing, we noted that the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 3 of 8 students.
Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files.
Effect: The University is not maintaining proper documentation in student files.
Repeat Finding: Yes, prior year finding 2022-005.
Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures.
Condition: During our testing, it was noted 3 of 8 students did not have the required support in their student files.
Questioned Costs: None
Context: During our testing, we noted that the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 3 of 8 students.
Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files.
Effect: The University is not maintaining proper documentation in student files.
Repeat Finding: Yes, prior year finding 2022-005.
Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures.
Condition: During our testing, it was noted 3 of 8 students did not have the required support in their student files.
Questioned Costs: None
Context: During our testing, we noted that the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 3 of 8 students.
Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files.
Effect: The University is not maintaining proper documentation in student files.
Repeat Finding: Yes, prior year finding 2022-005.
Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures.
Condition: During our testing, it was noted 3 of 8 students did not have the required support in their student files.
Questioned Costs: None
Context: During our testing, we noted that the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 3 of 8 students.
Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files.
Effect: The University is not maintaining proper documentation in student files.
Repeat Finding: Yes, prior year finding 2022-005.
Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures.
Condition: During our testing, it was noted 3 of 8 students did not have the required support in their student files.
Questioned Costs: None
Context: During our testing, we noted that the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 3 of 8 students.
Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files.
Effect: The University is not maintaining proper documentation in student files.
Repeat Finding: Yes, prior year finding 2022-005.
Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures.
Condition: During our testing, it was noted 3 of 8 students did not have the required support in their student files.
Questioned Costs: None
Context: During our testing, we noted that the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 3 of 8 students.
Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files.
Effect: The University is not maintaining proper documentation in student files.
Repeat Finding: Yes, prior year finding 2022-005.
Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors.
Condition: During our testing, we noted 1 student out of 35 where the subsidized direct loan awarded was over the maximum eligible amount.
Questioned Costs: $2,275
Context: During our testing, it was noted that 1 student's Title IV was not reallocated properly based on their EFC and outside scholarships they received, therefore, they were over awarded subsidized loans by $2,275.
Cause: The University did not reallocate Title IV funds properly based on need and other estimated financial assistance.
Effect: The student was not eligible for the specific awarded amount.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and a policy around packaging Title IV based on need.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Department of Education requires institutions 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 disbursements tested was not reported within the required 15 days.
Questioned Costs: None
Context: During our testing, one of the disbursements was not reported to COD within the required 15 days.
Cause: There was turnover at the University and this process was supposed to be running automatically, however, the system was not working properly. As a result, the manual process of reporting to COD was not completed timely.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Department of Education requires institutions 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 disbursements tested was not reported within the required 15 days.
Questioned Costs: None
Context: During our testing, one of the disbursements was not reported to COD within the required 15 days.
Cause: There was turnover at the University and this process was supposed to be running automatically, however, the system was not working properly. As a result, the manual process of reporting to COD was not completed timely.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)).
Condition: During our testing, it was noted that the incorrect last day of attendance was used as the date of withdrawal for 2 students.
Questioned Costs: $706
Context: During our testing, we noted 2 out of 6 instances where the University mistakenly put the incorrect withdrawal date into the R2T4 calculation.
Cause: R2T4 calculations are not being accurately performed.
Effect: The University did not complete an accurate calculation as defined by Federal Regulations.
Repeat Finding: No.
Recommendation: We recommend the University review all R2T4 calculations to ensure the correct date of withdrawal is being used for all Title IV aid.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)).
Condition: During our testing, it was noted that the incorrect last day of attendance was used as the date of withdrawal for 2 students.
Questioned Costs: $706
Context: During our testing, we noted 2 out of 6 instances where the University mistakenly put the incorrect withdrawal date into the R2T4 calculation.
Cause: R2T4 calculations are not being accurately performed.
Effect: The University did not complete an accurate calculation as defined by Federal Regulations.
Repeat Finding: No.
Recommendation: We recommend the University review all R2T4 calculations to ensure the correct date of withdrawal is being used for all Title IV aid.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)).
Condition: During our testing, it was noted that the incorrect last day of attendance was used as the date of withdrawal for 2 students.
Questioned Costs: $706
Context: During our testing, we noted 2 out of 6 instances where the University mistakenly put the incorrect withdrawal date into the R2T4 calculation.
Cause: R2T4 calculations are not being accurately performed.
Effect: The University did not complete an accurate calculation as defined by Federal Regulations.
Repeat Finding: No.
Recommendation: We recommend the University review all R2T4 calculations to ensure the correct date of withdrawal is being used for all Title IV aid.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)).
Condition: During our testing, it was noted that the incorrect last day of attendance was used as the date of withdrawal for 2 students.
Questioned Costs: $706
Context: During our testing, we noted 2 out of 6 instances where the University mistakenly put the incorrect withdrawal date into the R2T4 calculation.
Cause: R2T4 calculations are not being accurately performed.
Effect: The University did not complete an accurate calculation as defined by Federal Regulations.
Repeat Finding: No.
Recommendation: We recommend the University review all R2T4 calculations to ensure the correct date of withdrawal is being used for all Title IV aid.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)).
Condition: During our testing, it was noted that the incorrect last day of attendance was used as the date of withdrawal for 2 students.
Questioned Costs: $706
Context: During our testing, we noted 2 out of 6 instances where the University mistakenly put the incorrect withdrawal date into the R2T4 calculation.
Cause: R2T4 calculations are not being accurately performed.
Effect: The University did not complete an accurate calculation as defined by Federal Regulations.
Repeat Finding: No.
Recommendation: We recommend the University review all R2T4 calculations to ensure the correct date of withdrawal is being used for all Title IV aid.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)).
Condition: During our testing, it was noted that the incorrect last day of attendance was used as the date of withdrawal for 2 students.
Questioned Costs: $706
Context: During our testing, we noted 2 out of 6 instances where the University mistakenly put the incorrect withdrawal date into the R2T4 calculation.
Cause: R2T4 calculations are not being accurately performed.
Effect: The University did not complete an accurate calculation as defined by Federal Regulations.
Repeat Finding: No.
Recommendation: We recommend the University review all R2T4 calculations to ensure the correct date of withdrawal is being used for all Title IV aid.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Condition: During our testing, we noted instances where student enrollment status changes were incorrectly reported to NSLDS.
Questioned Costs: None
Context: Out of a sample of 40 students selected for testing, we noted the following:
2 students were reported with the incorrect enrollment status at both the campus and program
levels.
1 student was reported with the incorrect enrollment status at the program level
Cause: Due to turnover in the Registrar’s office, status changes were not reported accurately.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat Finding: Yes, prior year finding 2022-002.
Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Condition: During our testing, we noted instances where student enrollment status changes were incorrectly reported to NSLDS.
Questioned Costs: None
Context: Out of a sample of 40 students selected for testing, we noted the following:
2 students were reported with the incorrect enrollment status at both the campus and program
levels.
1 student was reported with the incorrect enrollment status at the program level
Cause: Due to turnover in the Registrar’s office, status changes were not reported accurately.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat Finding: Yes, prior year finding 2022-002.
Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: During testing of cash management, there was no approval support for 2 of 6 Title IV drawdowns selected for testing.
Questioned Costs: None
Context: During our testing cash management, the University was unable to locate documented approval for 2 of 6 drawdown selections.
Cause: There was turnover throughout the year and a paper trail was not always maintained.
Effect: Documentation was not maintained to support the review and approval of drawdowns made by management.
Repeat Finding: No.
Recommendation: We recommend that the University ensure proper evidence of approval is maintained for all Title IV drawdowns.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: During testing of cash management, there was no approval support for 2 of 6 Title IV drawdowns selected for testing.
Questioned Costs: None
Context: During our testing cash management, the University was unable to locate documented approval for 2 of 6 drawdown selections.
Cause: There was turnover throughout the year and a paper trail was not always maintained.
Effect: Documentation was not maintained to support the review and approval of drawdowns made by management.
Repeat Finding: No.
Recommendation: We recommend that the University ensure proper evidence of approval is maintained for all Title IV drawdowns.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: During testing of cash management, there was no approval support for 2 of 6 Title IV drawdowns selected for testing.
Questioned Costs: None
Context: During our testing cash management, the University was unable to locate documented approval for 2 of 6 drawdown selections.
Cause: There was turnover throughout the year and a paper trail was not always maintained.
Effect: Documentation was not maintained to support the review and approval of drawdowns made by management.
Repeat Finding: No.
Recommendation: We recommend that the University ensure proper evidence of approval is maintained for all Title IV drawdowns.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: During testing of cash management, there was no approval support for 2 of 6 Title IV drawdowns selected for testing.
Questioned Costs: None
Context: During our testing cash management, the University was unable to locate documented approval for 2 of 6 drawdown selections.
Cause: There was turnover throughout the year and a paper trail was not always maintained.
Effect: Documentation was not maintained to support the review and approval of drawdowns made by management.
Repeat Finding: No.
Recommendation: We recommend that the University ensure proper evidence of approval is maintained for all Title IV drawdowns.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: During testing of cash management, there was no approval support for 2 of 6 Title IV drawdowns selected for testing.
Questioned Costs: None
Context: During our testing cash management, the University was unable to locate documented approval for 2 of 6 drawdown selections.
Cause: There was turnover throughout the year and a paper trail was not always maintained.
Effect: Documentation was not maintained to support the review and approval of drawdowns made by management.
Repeat Finding: No.
Recommendation: We recommend that the University ensure proper evidence of approval is maintained for all Title IV drawdowns.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions.
Condition: During testing of cash management, there was no approval support for 2 of 6 Title IV drawdowns selected for testing.
Questioned Costs: None
Context: During our testing cash management, the University was unable to locate documented approval for 2 of 6 drawdown selections.
Cause: There was turnover throughout the year and a paper trail was not always maintained.
Effect: Documentation was not maintained to support the review and approval of drawdowns made by management.
Repeat Finding: No.
Recommendation: We recommend that the University ensure proper evidence of approval is maintained for all Title IV drawdowns.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires an institution to reconcile their records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary monthly.
Condition: Direct loan reconciliations between the COD, G5 and student accounts were not being documented as performed during the year.
Questioned Costs: None
Context: While testing direct loan reconciliations, it was noted that the University was reconciling direct loan activity nearly daily. However, the University did not maintain supporting documentation that the reconciliation process took place.
Cause: There was turnover at the University during the year and not all documentation was maintained or could be located.
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. There should be a process to maintain all reconciliations to support these were performed as required monthly.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures.
Condition: During our testing, it was noted 3 of 8 students did not have the required support in their student files.
Questioned Costs: None
Context: During our testing, we noted that the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 3 of 8 students.
Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files.
Effect: The University is not maintaining proper documentation in student files.
Repeat Finding: Yes, prior year finding 2022-005.
Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures.
Condition: During our testing, it was noted 3 of 8 students did not have the required support in their student files.
Questioned Costs: None
Context: During our testing, we noted that the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 3 of 8 students.
Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files.
Effect: The University is not maintaining proper documentation in student files.
Repeat Finding: Yes, prior year finding 2022-005.
Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures.
Condition: During our testing, it was noted 3 of 8 students did not have the required support in their student files.
Questioned Costs: None
Context: During our testing, we noted that the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 3 of 8 students.
Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files.
Effect: The University is not maintaining proper documentation in student files.
Repeat Finding: Yes, prior year finding 2022-005.
Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures.
Condition: During our testing, it was noted 3 of 8 students did not have the required support in their student files.
Questioned Costs: None
Context: During our testing, we noted that the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 3 of 8 students.
Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files.
Effect: The University is not maintaining proper documentation in student files.
Repeat Finding: Yes, prior year finding 2022-005.
Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures.
Condition: During our testing, it was noted 3 of 8 students did not have the required support in their student files.
Questioned Costs: None
Context: During our testing, we noted that the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 3 of 8 students.
Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files.
Effect: The University is not maintaining proper documentation in student files.
Repeat Finding: Yes, prior year finding 2022-005.
Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures.
Condition: During our testing, it was noted 3 of 8 students did not have the required support in their student files.
Questioned Costs: None
Context: During our testing, we noted that the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 3 of 8 students.
Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files.
Effect: The University is not maintaining proper documentation in student files.
Repeat Finding: Yes, prior year finding 2022-005.
Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors.
Condition: During our testing, we noted 1 student out of 35 where the subsidized direct loan awarded was over the maximum eligible amount.
Questioned Costs: $2,275
Context: During our testing, it was noted that 1 student's Title IV was not reallocated properly based on their EFC and outside scholarships they received, therefore, they were over awarded subsidized loans by $2,275.
Cause: The University did not reallocate Title IV funds properly based on need and other estimated financial assistance.
Effect: The student was not eligible for the specific awarded amount.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and a policy around packaging Title IV based on need.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Department of Education requires institutions 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 disbursements tested was not reported within the required 15 days.
Questioned Costs: None
Context: During our testing, one of the disbursements was not reported to COD within the required 15 days.
Cause: There was turnover at the University and this process was supposed to be running automatically, however, the system was not working properly. As a result, the manual process of reporting to COD was not completed timely.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Department of Education requires institutions 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 disbursements tested was not reported within the required 15 days.
Questioned Costs: None
Context: During our testing, one of the disbursements was not reported to COD within the required 15 days.
Cause: There was turnover at the University and this process was supposed to be running automatically, however, the system was not working properly. As a result, the manual process of reporting to COD was not completed timely.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)).
Condition: During our testing, it was noted that the incorrect last day of attendance was used as the date of withdrawal for 2 students.
Questioned Costs: $706
Context: During our testing, we noted 2 out of 6 instances where the University mistakenly put the incorrect withdrawal date into the R2T4 calculation.
Cause: R2T4 calculations are not being accurately performed.
Effect: The University did not complete an accurate calculation as defined by Federal Regulations.
Repeat Finding: No.
Recommendation: We recommend the University review all R2T4 calculations to ensure the correct date of withdrawal is being used for all Title IV aid.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)).
Condition: During our testing, it was noted that the incorrect last day of attendance was used as the date of withdrawal for 2 students.
Questioned Costs: $706
Context: During our testing, we noted 2 out of 6 instances where the University mistakenly put the incorrect withdrawal date into the R2T4 calculation.
Cause: R2T4 calculations are not being accurately performed.
Effect: The University did not complete an accurate calculation as defined by Federal Regulations.
Repeat Finding: No.
Recommendation: We recommend the University review all R2T4 calculations to ensure the correct date of withdrawal is being used for all Title IV aid.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)).
Condition: During our testing, it was noted that the incorrect last day of attendance was used as the date of withdrawal for 2 students.
Questioned Costs: $706
Context: During our testing, we noted 2 out of 6 instances where the University mistakenly put the incorrect withdrawal date into the R2T4 calculation.
Cause: R2T4 calculations are not being accurately performed.
Effect: The University did not complete an accurate calculation as defined by Federal Regulations.
Repeat Finding: No.
Recommendation: We recommend the University review all R2T4 calculations to ensure the correct date of withdrawal is being used for all Title IV aid.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)).
Condition: During our testing, it was noted that the incorrect last day of attendance was used as the date of withdrawal for 2 students.
Questioned Costs: $706
Context: During our testing, we noted 2 out of 6 instances where the University mistakenly put the incorrect withdrawal date into the R2T4 calculation.
Cause: R2T4 calculations are not being accurately performed.
Effect: The University did not complete an accurate calculation as defined by Federal Regulations.
Repeat Finding: No.
Recommendation: We recommend the University review all R2T4 calculations to ensure the correct date of withdrawal is being used for all Title IV aid.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)).
Condition: During our testing, it was noted that the incorrect last day of attendance was used as the date of withdrawal for 2 students.
Questioned Costs: $706
Context: During our testing, we noted 2 out of 6 instances where the University mistakenly put the incorrect withdrawal date into the R2T4 calculation.
Cause: R2T4 calculations are not being accurately performed.
Effect: The University did not complete an accurate calculation as defined by Federal Regulations.
Repeat Finding: No.
Recommendation: We recommend the University review all R2T4 calculations to ensure the correct date of withdrawal is being used for all Title IV aid.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)).
Condition: During our testing, it was noted that the incorrect last day of attendance was used as the date of withdrawal for 2 students.
Questioned Costs: $706
Context: During our testing, we noted 2 out of 6 instances where the University mistakenly put the incorrect withdrawal date into the R2T4 calculation.
Cause: R2T4 calculations are not being accurately performed.
Effect: The University did not complete an accurate calculation as defined by Federal Regulations.
Repeat Finding: No.
Recommendation: We recommend the University review all R2T4 calculations to ensure the correct date of withdrawal is being used for all Title IV aid.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Condition: During our testing, we noted instances where student enrollment status changes were incorrectly reported to NSLDS.
Questioned Costs: None
Context: Out of a sample of 40 students selected for testing, we noted the following:
2 students were reported with the incorrect enrollment status at both the campus and program
levels.
1 student was reported with the incorrect enrollment status at the program level
Cause: Due to turnover in the Registrar’s office, status changes were not reported accurately.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat Finding: Yes, prior year finding 2022-002.
Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations.
Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Condition: During our testing, we noted instances where student enrollment status changes were incorrectly reported to NSLDS.
Questioned Costs: None
Context: Out of a sample of 40 students selected for testing, we noted the following:
2 students were reported with the incorrect enrollment status at both the campus and program
levels.
1 student was reported with the incorrect enrollment status at the program level
Cause: Due to turnover in the Registrar’s office, status changes were not reported accurately.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat Finding: Yes, prior year finding 2022-002.
Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations.
Views of Responsible Officials: Management agrees with the finding.