Lack of Administrative Capability Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations.
Criteria: 34 CFR 668.16
Questioned Costs: $498,771
Context: In the current year, we found several areas of noncompliance and one repeated finding with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid.
Cause: The University continued to have staffing challenges and were still in process on addressing prior year findings.
Effect: Noncompliance with a number of Title IV regulations.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University adjust the financial aid system to allow for more checks and balances, correct the withdrawal system errors, and implement more robust review procedures.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations.
Criteria: 34 CFR 668.16
Questioned Costs: $498,771
Context: In the current year, we found several areas of noncompliance and one repeated finding with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid.
Cause: The University continued to have staffing challenges and were still in process on addressing prior year findings.
Effect: Noncompliance with a number of Title IV regulations.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University adjust the financial aid system to allow for more checks and balances, correct the withdrawal system errors, and implement more robust review procedures.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations.
Criteria: 34 CFR 668.16
Questioned Costs: $498,771
Context: In the current year, we found several areas of noncompliance and one repeated finding with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid.
Cause: The University continued to have staffing challenges and were still in process on addressing prior year findings.
Effect: Noncompliance with a number of Title IV regulations.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University adjust the financial aid system to allow for more checks and balances, correct the withdrawal system errors, and implement more robust review procedures.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations.
Criteria: 34 CFR 668.16
Questioned Costs: $498,771
Context: In the current year, we found several areas of noncompliance and one repeated finding with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid.
Cause: The University continued to have staffing challenges and were still in process on addressing prior year findings.
Effect: Noncompliance with a number of Title IV regulations.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University adjust the financial aid system to allow for more checks and balances, correct the withdrawal system errors, and implement more robust review procedures.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations.
Criteria: 34 CFR 668.16
Questioned Costs: $498,771
Context: In the current year, we found several areas of noncompliance and one repeated finding with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid.
Cause: The University continued to have staffing challenges and were still in process on addressing prior year findings.
Effect: Noncompliance with a number of Title IV regulations.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University adjust the financial aid system to allow for more checks and balances, correct the withdrawal system errors, and implement more robust review procedures.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations.
Criteria: 34 CFR 668.16
Questioned Costs: $498,771
Context: In the current year, we found several areas of noncompliance and one repeated finding with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid.
Cause: The University continued to have staffing challenges and were still in process on addressing prior year findings.
Effect: Noncompliance with a number of Title IV regulations.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University adjust the financial aid system to allow for more checks and balances, correct the withdrawal system errors, and implement more robust review procedures.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.379
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $12,304
Context: Out of 51 withdrawal students tested, we noted a total of 11 students that had a late return of Title IV aid and their return amounts totaled $12,304. For these 11 returns, 6 of them were inaccurate resulting in 4 students under awarded $1,727 and 2 students over awarded $514. We noted an additional 5 students with inaccurate but timely returns resulting in the students being under awarded $8,786.
Cause: We noted this was caused by continued challenges with the complexity of modular withdrawal regulations, particularly due to a high number of students with all failing grades in these programs. Additionally the financial aid office is not receiving attendance details timely to process returns timely. The inaccurate returns were caused by using incorrect calendars or the system taking off all aid and these amounts were not included in the amounts that could have been disbursed in the calculations.
Effect: Incorrect amount of unearned or earned Title IV funds returned and untimely returns.
Identification as repeat finding, if applicable: 2022-002
Recommendation: We continue to recommend that the financial aid office work with the registrar office and those monitoring attendance to ensure that students who stop attending after 2 weeks are followed up on timely to determine if R2T4's are required and ensure that funds are returned within the required 45 days. We also continue to recommend the University have a secondary review of each calendar set up for R2T4 calculations to ensure the correct number of days is used.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.379
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $12,304
Context: Out of 51 withdrawal students tested, we noted a total of 11 students that had a late return of Title IV aid and their return amounts totaled $12,304. For these 11 returns, 6 of them were inaccurate resulting in 4 students under awarded $1,727 and 2 students over awarded $514. We noted an additional 5 students with inaccurate but timely returns resulting in the students being under awarded $8,786.
Cause: We noted this was caused by continued challenges with the complexity of modular withdrawal regulations, particularly due to a high number of students with all failing grades in these programs. Additionally the financial aid office is not receiving attendance details timely to process returns timely. The inaccurate returns were caused by using incorrect calendars or the system taking off all aid and these amounts were not included in the amounts that could have been disbursed in the calculations.
Effect: Incorrect amount of unearned or earned Title IV funds returned and untimely returns.
Identification as repeat finding, if applicable: 2022-002
Recommendation: We continue to recommend that the financial aid office work with the registrar office and those monitoring attendance to ensure that students who stop attending after 2 weeks are followed up on timely to determine if R2T4's are required and ensure that funds are returned within the required 45 days. We also continue to recommend the University have a secondary review of each calendar set up for R2T4 calculations to ensure the correct number of days is used.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.379
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $12,304
Context: Out of 51 withdrawal students tested, we noted a total of 11 students that had a late return of Title IV aid and their return amounts totaled $12,304. For these 11 returns, 6 of them were inaccurate resulting in 4 students under awarded $1,727 and 2 students over awarded $514. We noted an additional 5 students with inaccurate but timely returns resulting in the students being under awarded $8,786.
Cause: We noted this was caused by continued challenges with the complexity of modular withdrawal regulations, particularly due to a high number of students with all failing grades in these programs. Additionally the financial aid office is not receiving attendance details timely to process returns timely. The inaccurate returns were caused by using incorrect calendars or the system taking off all aid and these amounts were not included in the amounts that could have been disbursed in the calculations.
Effect: Incorrect amount of unearned or earned Title IV funds returned and untimely returns.
Identification as repeat finding, if applicable: 2022-002
Recommendation: We continue to recommend that the financial aid office work with the registrar office and those monitoring attendance to ensure that students who stop attending after 2 weeks are followed up on timely to determine if R2T4's are required and ensure that funds are returned within the required 45 days. We also continue to recommend the University have a secondary review of each calendar set up for R2T4 calculations to ensure the correct number of days is used.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.379
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $12,304
Context: Out of 51 withdrawal students tested, we noted a total of 11 students that had a late return of Title IV aid and their return amounts totaled $12,304. For these 11 returns, 6 of them were inaccurate resulting in 4 students under awarded $1,727 and 2 students over awarded $514. We noted an additional 5 students with inaccurate but timely returns resulting in the students being under awarded $8,786.
Cause: We noted this was caused by continued challenges with the complexity of modular withdrawal regulations, particularly due to a high number of students with all failing grades in these programs. Additionally the financial aid office is not receiving attendance details timely to process returns timely. The inaccurate returns were caused by using incorrect calendars or the system taking off all aid and these amounts were not included in the amounts that could have been disbursed in the calculations.
Effect: Incorrect amount of unearned or earned Title IV funds returned and untimely returns.
Identification as repeat finding, if applicable: 2022-002
Recommendation: We continue to recommend that the financial aid office work with the registrar office and those monitoring attendance to ensure that students who stop attending after 2 weeks are followed up on timely to determine if R2T4's are required and ensure that funds are returned within the required 45 days. We also continue to recommend the University have a secondary review of each calendar set up for R2T4 calculations to ensure the correct number of days is used.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Emergency Relief Fund (HEERF) Earmarking Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.425E and 84.425F
Federal Award Identification #: P425E200101, P425F201431
Condition: The University had drawn all their authorized HEERF funds by the end of the performance period but did not fully spend the student portion, therefore the University did not meet the earmarking requirements for the minimum amount of HEERF funds spent on student grants.
Criteria: CARES Act section 18004 (a) (1), CRRSAA Act section 314 (a) (1), ARP Act
Questioned Costs: $436,565
Context: The University did not have support for providing $193,858 of grants to students from the HEERF student portion (84.425E) which represents the University's remaining available authorization at the beginning of fiscal year 2023. Due to not fully spending this student portion, this disallowed a prorated amount totaling $242,707 of the institutional portion (84.425F) given the conditions and earmarking requirements for HEERF.
Cause: Inadequate reconciliation of HEERF expenditures and drawdowns and lack of review at the end of period of performance.
Effect: Since the student grant minimum was not met, the University is not eligible for the full allocation of the institutional portion of the HEERF.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University return funds as applicable and as directed by Department of Education.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Emergency Relief Fund (HEERF) Earmarking Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.425E and 84.425F
Federal Award Identification #: P425E200101, P425F201431
Condition: The University had drawn all their authorized HEERF funds by the end of the performance period but did not fully spend the student portion, therefore the University did not meet the earmarking requirements for the minimum amount of HEERF funds spent on student grants.
Criteria: CARES Act section 18004 (a) (1), CRRSAA Act section 314 (a) (1), ARP Act
Questioned Costs: $436,565
Context: The University did not have support for providing $193,858 of grants to students from the HEERF student portion (84.425E) which represents the University's remaining available authorization at the beginning of fiscal year 2023. Due to not fully spending this student portion, this disallowed a prorated amount totaling $242,707 of the institutional portion (84.425F) given the conditions and earmarking requirements for HEERF.
Cause: Inadequate reconciliation of HEERF expenditures and drawdowns and lack of review at the end of period of performance.
Effect: Since the student grant minimum was not met, the University is not eligible for the full allocation of the institutional portion of the HEERF.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University return funds as applicable and as directed by Department of Education.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Ineligible Programs Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University awarded 34 students in ineligible graduate certificate programs therefore they were not eligible for federal aid.
Criteria: 34 CFR 668.8
Questioned Costs: $482,217
Context: During our audit, we identified a number of certificate programs that were not eligible for Title IV aid and in our comparison of these programs to the federal aid listing we identified 34 students that received federal aid.
Cause: This was a management oversight for students in a graduate certificate program that was previously eligible and students that were also previously enrolled in an eligible degree program along with a certificate program.
Effect: Students receiving federal aid that were not eligible to receive aid.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University implement system controls to prevent packaging students with federal aid that are only enrolled in an ineligible graduate certificate program.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor provided a written, annual report to the board.
Cause: The University has experienced significant turnover in IT personnel that has not allowed sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor provided a written, annual report to the board.
Cause: The University has experienced significant turnover in IT personnel that has not allowed sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor provided a written, annual report to the board.
Cause: The University has experienced significant turnover in IT personnel that has not allowed sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor provided a written, annual report to the board.
Cause: The University has experienced significant turnover in IT personnel that has not allowed sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor provided a written, annual report to the board.
Cause: The University has experienced significant turnover in IT personnel that has not allowed sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor provided a written, annual report to the board.
Cause: The University has experienced significant turnover in IT personnel that has not allowed sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Direct Loan (FDL) Monthly Reconciliations DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not adequately complete FDL monthly reconciliations every month and there was lack of support for review and approval.
Criteria: 34 CFR 685.300(b)(5)
Questioned Costs: $-0-
Context: During our audit we determined that the University did not have support for completing a FDL monthly reconciliation for several months during the fiscal year. The reconciliation that was tested in our audit did not have evidence of review and approval.
Cause: Turnover and staffing challenges in the financial aid office.
Effect: Noncompliance with reconciliation requirements which could lead to unreconciled differences going undetected or not being resolved timely.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend that the University review the reconciliation requirements and properly complete the mandatory monthly reconciliations for FDL. The University should also review or refer to the U.S. Department of Education (ED) announcement DL-22-07 which included information to assist higher education institutions with the mandatory reconciliation requirements for the FDL Program.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Aggregate Federal Direct Loan Limits DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not properly award a student based on their aggregate subsidized federal direct loan limit and disbursed them subsidized loans in excess of this limit.
Criteria: 34 CFR 665.203 (d)
Questioned Costs: $4,250
Context: During our audit we noted 1 student had received their annual max subsidized federal direct loan of $5,500 which this amount put the student over their aggregate subsidized federal direct loan limit by $4,250.
Cause: Management oversight.
Effect: The student is not eligible for Title IV federal aid if over award is not corrected.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend that the when students have an ISIR code which indicates the student may have received loans in excess of aggregate limits, the University resolve that issue prior to disbursing loans to ensure that the student isn't over awarded.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Cash Management DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not adequately maintain records for drawdowns of Federal Direct Loans (FDL) and Federal Pell Grants (Pell) to support compliance with cash management regulations.
Criteria: 34 CFR 668.162
Questioned Costs: $-0-
Context: During our audit, we tested 6 drawdowns of FDL and 6 drawdowns of Pell and each did not have adequate support for minimizing time between drawdown and disbursement. There did not appear to be a formal process nor clear understanding for the individual drawdown amounts. However the University provided a detail of federal aid disbursements to students thus we did a comparison of the year to date disbursements to the year to date drawdowns at the time of each drawdown tested. We noted the University did not appear to have drawn FDL and Pell funds in excess of disbursements based on this testing.
Cause: Management oversight
Effect: Potential noncompliance with cash management requirements and lack of proper record retention.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend that the University implement and follow a formal process for making drawdowns and require that supporting documentation include evidence of review and approval and be retained to support compliance with cash management requirements.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Cash Management DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not adequately maintain records for drawdowns of Federal Direct Loans (FDL) and Federal Pell Grants (Pell) to support compliance with cash management regulations.
Criteria: 34 CFR 668.162
Questioned Costs: $-0-
Context: During our audit, we tested 6 drawdowns of FDL and 6 drawdowns of Pell and each did not have adequate support for minimizing time between drawdown and disbursement. There did not appear to be a formal process nor clear understanding for the individual drawdown amounts. However the University provided a detail of federal aid disbursements to students thus we did a comparison of the year to date disbursements to the year to date drawdowns at the time of each drawdown tested. We noted the University did not appear to have drawn FDL and Pell funds in excess of disbursements based on this testing.
Cause: Management oversight
Effect: Potential noncompliance with cash management requirements and lack of proper record retention.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend that the University implement and follow a formal process for making drawdowns and require that supporting documentation include evidence of review and approval and be retained to support compliance with cash management requirements.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations.
Criteria: 34 CFR 668.16
Questioned Costs: $498,771
Context: In the current year, we found several areas of noncompliance and one repeated finding with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid.
Cause: The University continued to have staffing challenges and were still in process on addressing prior year findings.
Effect: Noncompliance with a number of Title IV regulations.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University adjust the financial aid system to allow for more checks and balances, correct the withdrawal system errors, and implement more robust review procedures.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations.
Criteria: 34 CFR 668.16
Questioned Costs: $498,771
Context: In the current year, we found several areas of noncompliance and one repeated finding with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid.
Cause: The University continued to have staffing challenges and were still in process on addressing prior year findings.
Effect: Noncompliance with a number of Title IV regulations.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University adjust the financial aid system to allow for more checks and balances, correct the withdrawal system errors, and implement more robust review procedures.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations.
Criteria: 34 CFR 668.16
Questioned Costs: $498,771
Context: In the current year, we found several areas of noncompliance and one repeated finding with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid.
Cause: The University continued to have staffing challenges and were still in process on addressing prior year findings.
Effect: Noncompliance with a number of Title IV regulations.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University adjust the financial aid system to allow for more checks and balances, correct the withdrawal system errors, and implement more robust review procedures.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations.
Criteria: 34 CFR 668.16
Questioned Costs: $498,771
Context: In the current year, we found several areas of noncompliance and one repeated finding with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid.
Cause: The University continued to have staffing challenges and were still in process on addressing prior year findings.
Effect: Noncompliance with a number of Title IV regulations.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University adjust the financial aid system to allow for more checks and balances, correct the withdrawal system errors, and implement more robust review procedures.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations.
Criteria: 34 CFR 668.16
Questioned Costs: $498,771
Context: In the current year, we found several areas of noncompliance and one repeated finding with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid.
Cause: The University continued to have staffing challenges and were still in process on addressing prior year findings.
Effect: Noncompliance with a number of Title IV regulations.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University adjust the financial aid system to allow for more checks and balances, correct the withdrawal system errors, and implement more robust review procedures.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Administrative Capability Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations.
Criteria: 34 CFR 668.16
Questioned Costs: $498,771
Context: In the current year, we found several areas of noncompliance and one repeated finding with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid.
Cause: The University continued to have staffing challenges and were still in process on addressing prior year findings.
Effect: Noncompliance with a number of Title IV regulations.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University adjust the financial aid system to allow for more checks and balances, correct the withdrawal system errors, and implement more robust review procedures.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.379
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $12,304
Context: Out of 51 withdrawal students tested, we noted a total of 11 students that had a late return of Title IV aid and their return amounts totaled $12,304. For these 11 returns, 6 of them were inaccurate resulting in 4 students under awarded $1,727 and 2 students over awarded $514. We noted an additional 5 students with inaccurate but timely returns resulting in the students being under awarded $8,786.
Cause: We noted this was caused by continued challenges with the complexity of modular withdrawal regulations, particularly due to a high number of students with all failing grades in these programs. Additionally the financial aid office is not receiving attendance details timely to process returns timely. The inaccurate returns were caused by using incorrect calendars or the system taking off all aid and these amounts were not included in the amounts that could have been disbursed in the calculations.
Effect: Incorrect amount of unearned or earned Title IV funds returned and untimely returns.
Identification as repeat finding, if applicable: 2022-002
Recommendation: We continue to recommend that the financial aid office work with the registrar office and those monitoring attendance to ensure that students who stop attending after 2 weeks are followed up on timely to determine if R2T4's are required and ensure that funds are returned within the required 45 days. We also continue to recommend the University have a secondary review of each calendar set up for R2T4 calculations to ensure the correct number of days is used.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.379
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $12,304
Context: Out of 51 withdrawal students tested, we noted a total of 11 students that had a late return of Title IV aid and their return amounts totaled $12,304. For these 11 returns, 6 of them were inaccurate resulting in 4 students under awarded $1,727 and 2 students over awarded $514. We noted an additional 5 students with inaccurate but timely returns resulting in the students being under awarded $8,786.
Cause: We noted this was caused by continued challenges with the complexity of modular withdrawal regulations, particularly due to a high number of students with all failing grades in these programs. Additionally the financial aid office is not receiving attendance details timely to process returns timely. The inaccurate returns were caused by using incorrect calendars or the system taking off all aid and these amounts were not included in the amounts that could have been disbursed in the calculations.
Effect: Incorrect amount of unearned or earned Title IV funds returned and untimely returns.
Identification as repeat finding, if applicable: 2022-002
Recommendation: We continue to recommend that the financial aid office work with the registrar office and those monitoring attendance to ensure that students who stop attending after 2 weeks are followed up on timely to determine if R2T4's are required and ensure that funds are returned within the required 45 days. We also continue to recommend the University have a secondary review of each calendar set up for R2T4 calculations to ensure the correct number of days is used.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.379
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $12,304
Context: Out of 51 withdrawal students tested, we noted a total of 11 students that had a late return of Title IV aid and their return amounts totaled $12,304. For these 11 returns, 6 of them were inaccurate resulting in 4 students under awarded $1,727 and 2 students over awarded $514. We noted an additional 5 students with inaccurate but timely returns resulting in the students being under awarded $8,786.
Cause: We noted this was caused by continued challenges with the complexity of modular withdrawal regulations, particularly due to a high number of students with all failing grades in these programs. Additionally the financial aid office is not receiving attendance details timely to process returns timely. The inaccurate returns were caused by using incorrect calendars or the system taking off all aid and these amounts were not included in the amounts that could have been disbursed in the calculations.
Effect: Incorrect amount of unearned or earned Title IV funds returned and untimely returns.
Identification as repeat finding, if applicable: 2022-002
Recommendation: We continue to recommend that the financial aid office work with the registrar office and those monitoring attendance to ensure that students who stop attending after 2 weeks are followed up on timely to determine if R2T4's are required and ensure that funds are returned within the required 45 days. We also continue to recommend the University have a secondary review of each calendar set up for R2T4 calculations to ensure the correct number of days is used.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.379
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $12,304
Context: Out of 51 withdrawal students tested, we noted a total of 11 students that had a late return of Title IV aid and their return amounts totaled $12,304. For these 11 returns, 6 of them were inaccurate resulting in 4 students under awarded $1,727 and 2 students over awarded $514. We noted an additional 5 students with inaccurate but timely returns resulting in the students being under awarded $8,786.
Cause: We noted this was caused by continued challenges with the complexity of modular withdrawal regulations, particularly due to a high number of students with all failing grades in these programs. Additionally the financial aid office is not receiving attendance details timely to process returns timely. The inaccurate returns were caused by using incorrect calendars or the system taking off all aid and these amounts were not included in the amounts that could have been disbursed in the calculations.
Effect: Incorrect amount of unearned or earned Title IV funds returned and untimely returns.
Identification as repeat finding, if applicable: 2022-002
Recommendation: We continue to recommend that the financial aid office work with the registrar office and those monitoring attendance to ensure that students who stop attending after 2 weeks are followed up on timely to determine if R2T4's are required and ensure that funds are returned within the required 45 days. We also continue to recommend the University have a secondary review of each calendar set up for R2T4 calculations to ensure the correct number of days is used.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Emergency Relief Fund (HEERF) Earmarking Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.425E and 84.425F
Federal Award Identification #: P425E200101, P425F201431
Condition: The University had drawn all their authorized HEERF funds by the end of the performance period but did not fully spend the student portion, therefore the University did not meet the earmarking requirements for the minimum amount of HEERF funds spent on student grants.
Criteria: CARES Act section 18004 (a) (1), CRRSAA Act section 314 (a) (1), ARP Act
Questioned Costs: $436,565
Context: The University did not have support for providing $193,858 of grants to students from the HEERF student portion (84.425E) which represents the University's remaining available authorization at the beginning of fiscal year 2023. Due to not fully spending this student portion, this disallowed a prorated amount totaling $242,707 of the institutional portion (84.425F) given the conditions and earmarking requirements for HEERF.
Cause: Inadequate reconciliation of HEERF expenditures and drawdowns and lack of review at the end of period of performance.
Effect: Since the student grant minimum was not met, the University is not eligible for the full allocation of the institutional portion of the HEERF.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University return funds as applicable and as directed by Department of Education.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Emergency Relief Fund (HEERF) Earmarking Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.425E and 84.425F
Federal Award Identification #: P425E200101, P425F201431
Condition: The University had drawn all their authorized HEERF funds by the end of the performance period but did not fully spend the student portion, therefore the University did not meet the earmarking requirements for the minimum amount of HEERF funds spent on student grants.
Criteria: CARES Act section 18004 (a) (1), CRRSAA Act section 314 (a) (1), ARP Act
Questioned Costs: $436,565
Context: The University did not have support for providing $193,858 of grants to students from the HEERF student portion (84.425E) which represents the University's remaining available authorization at the beginning of fiscal year 2023. Due to not fully spending this student portion, this disallowed a prorated amount totaling $242,707 of the institutional portion (84.425F) given the conditions and earmarking requirements for HEERF.
Cause: Inadequate reconciliation of HEERF expenditures and drawdowns and lack of review at the end of period of performance.
Effect: Since the student grant minimum was not met, the University is not eligible for the full allocation of the institutional portion of the HEERF.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University return funds as applicable and as directed by Department of Education.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Ineligible Programs Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University awarded 34 students in ineligible graduate certificate programs therefore they were not eligible for federal aid.
Criteria: 34 CFR 668.8
Questioned Costs: $482,217
Context: During our audit, we identified a number of certificate programs that were not eligible for Title IV aid and in our comparison of these programs to the federal aid listing we identified 34 students that received federal aid.
Cause: This was a management oversight for students in a graduate certificate program that was previously eligible and students that were also previously enrolled in an eligible degree program along with a certificate program.
Effect: Students receiving federal aid that were not eligible to receive aid.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University implement system controls to prevent packaging students with federal aid that are only enrolled in an ineligible graduate certificate program.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor provided a written, annual report to the board.
Cause: The University has experienced significant turnover in IT personnel that has not allowed sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor provided a written, annual report to the board.
Cause: The University has experienced significant turnover in IT personnel that has not allowed sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor provided a written, annual report to the board.
Cause: The University has experienced significant turnover in IT personnel that has not allowed sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor provided a written, annual report to the board.
Cause: The University has experienced significant turnover in IT personnel that has not allowed sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor provided a written, annual report to the board.
Cause: The University has experienced significant turnover in IT personnel that has not allowed sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 (Student Financial Assistance Cluster)
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor provided a written, annual report to the board.
Cause: The University has experienced significant turnover in IT personnel that has not allowed sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Direct Loan (FDL) Monthly Reconciliations DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not adequately complete FDL monthly reconciliations every month and there was lack of support for review and approval.
Criteria: 34 CFR 685.300(b)(5)
Questioned Costs: $-0-
Context: During our audit we determined that the University did not have support for completing a FDL monthly reconciliation for several months during the fiscal year. The reconciliation that was tested in our audit did not have evidence of review and approval.
Cause: Turnover and staffing challenges in the financial aid office.
Effect: Noncompliance with reconciliation requirements which could lead to unreconciled differences going undetected or not being resolved timely.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend that the University review the reconciliation requirements and properly complete the mandatory monthly reconciliations for FDL. The University should also review or refer to the U.S. Department of Education (ED) announcement DL-22-07 which included information to assist higher education institutions with the mandatory reconciliation requirements for the FDL Program.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Aggregate Federal Direct Loan Limits DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not properly award a student based on their aggregate subsidized federal direct loan limit and disbursed them subsidized loans in excess of this limit.
Criteria: 34 CFR 665.203 (d)
Questioned Costs: $4,250
Context: During our audit we noted 1 student had received their annual max subsidized federal direct loan of $5,500 which this amount put the student over their aggregate subsidized federal direct loan limit by $4,250.
Cause: Management oversight.
Effect: The student is not eligible for Title IV federal aid if over award is not corrected.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend that the when students have an ISIR code which indicates the student may have received loans in excess of aggregate limits, the University resolve that issue prior to disbursing loans to ensure that the student isn't over awarded.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Cash Management DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not adequately maintain records for drawdowns of Federal Direct Loans (FDL) and Federal Pell Grants (Pell) to support compliance with cash management regulations.
Criteria: 34 CFR 668.162
Questioned Costs: $-0-
Context: During our audit, we tested 6 drawdowns of FDL and 6 drawdowns of Pell and each did not have adequate support for minimizing time between drawdown and disbursement. There did not appear to be a formal process nor clear understanding for the individual drawdown amounts. However the University provided a detail of federal aid disbursements to students thus we did a comparison of the year to date disbursements to the year to date drawdowns at the time of each drawdown tested. We noted the University did not appear to have drawn FDL and Pell funds in excess of disbursements based on this testing.
Cause: Management oversight
Effect: Potential noncompliance with cash management requirements and lack of proper record retention.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend that the University implement and follow a formal process for making drawdowns and require that supporting documentation include evidence of review and approval and be retained to support compliance with cash management requirements.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Cash Management DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not adequately maintain records for drawdowns of Federal Direct Loans (FDL) and Federal Pell Grants (Pell) to support compliance with cash management regulations.
Criteria: 34 CFR 668.162
Questioned Costs: $-0-
Context: During our audit, we tested 6 drawdowns of FDL and 6 drawdowns of Pell and each did not have adequate support for minimizing time between drawdown and disbursement. There did not appear to be a formal process nor clear understanding for the individual drawdown amounts. However the University provided a detail of federal aid disbursements to students thus we did a comparison of the year to date disbursements to the year to date drawdowns at the time of each drawdown tested. We noted the University did not appear to have drawn FDL and Pell funds in excess of disbursements based on this testing.
Cause: Management oversight
Effect: Potential noncompliance with cash management requirements and lack of proper record retention.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend that the University implement and follow a formal process for making drawdowns and require that supporting documentation include evidence of review and approval and be retained to support compliance with cash management requirements.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.