Audit 299535

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grants ALN 84.063 and Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Changes in a student's status are required to be reported timely and accurately to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of a status change (Pell, 34 CFR Section 690.83(b)(2); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status changes timely to NSLDS. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, the University did not report status changes timely to NSLDS for six students who withdrew, ceasing to be enrolled on at least a half-time basis. For all six students, accurate status changes were reported within 75 days of the effective date. Cause and Effect - The University did not have a control in place to ensure that the timing of reporting of status changes to a third-party service provider, National Student Clearinghouse (NSC), was effectively designed to ensure that reporting from NSC to NSLDS resulted in compliance with the 60 day requirement. As a result, certain student changes were not reported to NSLDS within the required timeframe. Recommendation - The University should implement controls to ensure all student status changes are reported timely to NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University has implemented a change in the reporting timeline to ensure that there is adequate time between reporting to NSC and their reporting to NSLDS. In addition, the University will monitor reporting of status changes to NSLDS.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grants ALN 84.063 and Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Changes in a student's status are required to be reported timely and accurately to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of a status change (Pell, 34 CFR Section 690.83(b)(2); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status changes timely to NSLDS. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, the University did not report status changes timely to NSLDS for six students who withdrew, ceasing to be enrolled on at least a half-time basis. For all six students, accurate status changes were reported within 75 days of the effective date. Cause and Effect - The University did not have a control in place to ensure that the timing of reporting of status changes to a third-party service provider, National Student Clearinghouse (NSC), was effectively designed to ensure that reporting from NSC to NSLDS resulted in compliance with the 60 day requirement. As a result, certain student changes were not reported to NSLDS within the required timeframe. Recommendation - The University should implement controls to ensure all student status changes are reported timely to NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University has implemented a change in the reporting timeline to ensure that there is adequate time between reporting to NSC and their reporting to NSLDS. In addition, the University will monitor reporting of status changes to NSLDS.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grants ALN 84.063 and Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The University has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdrawals, or expresses notification to withdrawal, or if the student does not officially withdraw, the date the University determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition - The University did not return all Title IV funds in a timely manner due to a lack of communication and review. Questioned Costs - $485,231 Identification of How Questioned Costs Were Computed - The University identified all returns that should have been calculated during the fiscal year, performed the calculation for amounts not returned. Context - Of the 60 students tested, for six students, the University did not calculate the required return in a timely manner and did not return funds to the Department of Education within the required timeframe. All Title IV funds that were required to be returned were returned as of December 14, 2023. Cause and Effect - The University did not have adequate controls to communicate, calculate, and review, all returns in accordance with the regulations which resulted in late returns. Recommendation - We recommend implementing a control to ensure that all Title IV funds are returned within the required timeframe. Views of Responsible Officials and Planned Corrective Actions - Management has implemented the following corrective actions: -Beginning with the spring 2024 semester, an internal peer review process was implemented to verify that Title IV funds are returned within the required timeframe. This involves segregation of duties between the completion of each of the following: 1) official and unofficial withdrawal review, 2) verification of this review, and 3) return of the Title IV funding. -Beginning in February 2024, the process team leader within the Office of Student Aid is monitoring system reports on a periodic basis (weekly for official withdrawals, within 45 days of date of determination for unofficial withdrawals) to ensure procedures are being followed. -Beginning in February 2024 for the fall 2023 semester, quality control reviews are being conducted by the Office of Student Aid’s Compliance and Training Team in which withdrawn students are sampled to monitor compliance. These reviews will be conducted at the end of each semester going forward. -Management will update its Return to Title IV (“R2T4”) procedures to reflect these additional controls. Additionally, job aids related to R2T4 have been reviewed and updated where appropriate and ongoing training has been occurring with the R2T4 specialists.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grants ALN 84.063 and Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The University has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdrawals, or expresses notification to withdrawal, or if the student does not officially withdraw, the date the University determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition - The University did not return all Title IV funds in a timely manner due to a lack of communication and review. Questioned Costs - $485,231 Identification of How Questioned Costs Were Computed - The University identified all returns that should have been calculated during the fiscal year, performed the calculation for amounts not returned. Context - Of the 60 students tested, for six students, the University did not calculate the required return in a timely manner and did not return funds to the Department of Education within the required timeframe. All Title IV funds that were required to be returned were returned as of December 14, 2023. Cause and Effect - The University did not have adequate controls to communicate, calculate, and review, all returns in accordance with the regulations which resulted in late returns. Recommendation - We recommend implementing a control to ensure that all Title IV funds are returned within the required timeframe. Views of Responsible Officials and Planned Corrective Actions - Management has implemented the following corrective actions: -Beginning with the spring 2024 semester, an internal peer review process was implemented to verify that Title IV funds are returned within the required timeframe. This involves segregation of duties between the completion of each of the following: 1) official and unofficial withdrawal review, 2) verification of this review, and 3) return of the Title IV funding. -Beginning in February 2024, the process team leader within the Office of Student Aid is monitoring system reports on a periodic basis (weekly for official withdrawals, within 45 days of date of determination for unofficial withdrawals) to ensure procedures are being followed. -Beginning in February 2024 for the fall 2023 semester, quality control reviews are being conducted by the Office of Student Aid’s Compliance and Training Team in which withdrawn students are sampled to monitor compliance. These reviews will be conducted at the end of each semester going forward. -Management will update its Return to Title IV (“R2T4”) procedures to reflect these additional controls. Additionally, job aids related to R2T4 have been reviewed and updated where appropriate and ongoing training has been occurring with the R2T4 specialists.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grants ALN 84.063 and Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Changes in a student's status are required to be reported timely and accurately to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of a status change (Pell, 34 CFR Section 690.83(b)(2); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status changes timely to NSLDS. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, the University did not report status changes timely to NSLDS for six students who withdrew, ceasing to be enrolled on at least a half-time basis. For all six students, accurate status changes were reported within 75 days of the effective date. Cause and Effect - The University did not have a control in place to ensure that the timing of reporting of status changes to a third-party service provider, National Student Clearinghouse (NSC), was effectively designed to ensure that reporting from NSC to NSLDS resulted in compliance with the 60 day requirement. As a result, certain student changes were not reported to NSLDS within the required timeframe. Recommendation - The University should implement controls to ensure all student status changes are reported timely to NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University has implemented a change in the reporting timeline to ensure that there is adequate time between reporting to NSC and their reporting to NSLDS. In addition, the University will monitor reporting of status changes to NSLDS.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grants ALN 84.063 and Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Changes in a student's status are required to be reported timely and accurately to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of a status change (Pell, 34 CFR Section 690.83(b)(2); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status changes timely to NSLDS. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, the University did not report status changes timely to NSLDS for six students who withdrew, ceasing to be enrolled on at least a half-time basis. For all six students, accurate status changes were reported within 75 days of the effective date. Cause and Effect - The University did not have a control in place to ensure that the timing of reporting of status changes to a third-party service provider, National Student Clearinghouse (NSC), was effectively designed to ensure that reporting from NSC to NSLDS resulted in compliance with the 60 day requirement. As a result, certain student changes were not reported to NSLDS within the required timeframe. Recommendation - The University should implement controls to ensure all student status changes are reported timely to NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University has implemented a change in the reporting timeline to ensure that there is adequate time between reporting to NSC and their reporting to NSLDS. In addition, the University will monitor reporting of status changes to NSLDS.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grants ALN 84.063 and Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The University has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdrawals, or expresses notification to withdrawal, or if the student does not officially withdraw, the date the University determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition - The University did not return all Title IV funds in a timely manner due to a lack of communication and review. Questioned Costs - $485,231 Identification of How Questioned Costs Were Computed - The University identified all returns that should have been calculated during the fiscal year, performed the calculation for amounts not returned. Context - Of the 60 students tested, for six students, the University did not calculate the required return in a timely manner and did not return funds to the Department of Education within the required timeframe. All Title IV funds that were required to be returned were returned as of December 14, 2023. Cause and Effect - The University did not have adequate controls to communicate, calculate, and review, all returns in accordance with the regulations which resulted in late returns. Recommendation - We recommend implementing a control to ensure that all Title IV funds are returned within the required timeframe. Views of Responsible Officials and Planned Corrective Actions - Management has implemented the following corrective actions: -Beginning with the spring 2024 semester, an internal peer review process was implemented to verify that Title IV funds are returned within the required timeframe. This involves segregation of duties between the completion of each of the following: 1) official and unofficial withdrawal review, 2) verification of this review, and 3) return of the Title IV funding. -Beginning in February 2024, the process team leader within the Office of Student Aid is monitoring system reports on a periodic basis (weekly for official withdrawals, within 45 days of date of determination for unofficial withdrawals) to ensure procedures are being followed. -Beginning in February 2024 for the fall 2023 semester, quality control reviews are being conducted by the Office of Student Aid’s Compliance and Training Team in which withdrawn students are sampled to monitor compliance. These reviews will be conducted at the end of each semester going forward. -Management will update its Return to Title IV (“R2T4”) procedures to reflect these additional controls. Additionally, job aids related to R2T4 have been reviewed and updated where appropriate and ongoing training has been occurring with the R2T4 specialists.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grants ALN 84.063 and Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The University has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdrawals, or expresses notification to withdrawal, or if the student does not officially withdraw, the date the University determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition - The University did not return all Title IV funds in a timely manner due to a lack of communication and review. Questioned Costs - $485,231 Identification of How Questioned Costs Were Computed - The University identified all returns that should have been calculated during the fiscal year, performed the calculation for amounts not returned. Context - Of the 60 students tested, for six students, the University did not calculate the required return in a timely manner and did not return funds to the Department of Education within the required timeframe. All Title IV funds that were required to be returned were returned as of December 14, 2023. Cause and Effect - The University did not have adequate controls to communicate, calculate, and review, all returns in accordance with the regulations which resulted in late returns. Recommendation - We recommend implementing a control to ensure that all Title IV funds are returned within the required timeframe. Views of Responsible Officials and Planned Corrective Actions - Management has implemented the following corrective actions: -Beginning with the spring 2024 semester, an internal peer review process was implemented to verify that Title IV funds are returned within the required timeframe. This involves segregation of duties between the completion of each of the following: 1) official and unofficial withdrawal review, 2) verification of this review, and 3) return of the Title IV funding. -Beginning in February 2024, the process team leader within the Office of Student Aid is monitoring system reports on a periodic basis (weekly for official withdrawals, within 45 days of date of determination for unofficial withdrawals) to ensure procedures are being followed. -Beginning in February 2024 for the fall 2023 semester, quality control reviews are being conducted by the Office of Student Aid’s Compliance and Training Team in which withdrawn students are sampled to monitor compliance. These reviews will be conducted at the end of each semester going forward. -Management will update its Return to Title IV (“R2T4”) procedures to reflect these additional controls. Additionally, job aids related to R2T4 have been reviewed and updated where appropriate and ongoing training has been occurring with the R2T4 specialists.