Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($1,222,088) Award Number: P268K233315 and P26K223315 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: $-0- Condition Found: The incorrect enrollment status was reported to the National Student Loan Database System (“NSLDS”) for fourteen of the twenty-seven students selected for testing. Criteria: NSLDS informs loan servicers of changes in a student’s enrollment status that indicates when the repayments or interest accrual begins and ends. The date a student enrolls, withdraws, graduates, or drops below half-time status should be reported accurately. Cause: The University began working with a new third-party servicer in fiscal year 2021. The University was responsible for reporting enrollment status changes to the third-party servicer, and the third-party servicer was responsible for updating NSLDS. This process still continued to take longer than anticipated during fiscal year 2023. Possible Asserted Effect: The loan servicers were not aware of the correct deferral, repayment, and interest calculation dates. Repeat Finding: See Finding 2022-005 for a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Student Financial Aid Director should work with the third-party servicer to update the enrollment status of the eleven affected students in NSLDS. In addition, we recommend determining the amount of time the third-party servicer needs to process enrollment status changes. The University should make any necessary changes to its procedures or timeline for reporting enrollment status changes. Management Response: The Student Financial Aid Director corrected the enrollment status and withdrawal date for the students in question in November 2023. Procedures have been improved to ensure the information is communicated timely to the third-party servicer and that third-party servicer reports the changes to NSLDS timely.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($1,222,088) 84.063 ($554,113)M Award Number: P268K233315 P063P223315 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: $4,527 (84.268) $862 (84.063) Condition Found: The R2T4 calculation and Title IV funds were not returned or post-withdraw disbursements were not made timely for four of the twenty-seven students in the compliance testing sample. In addition, the R2T4 was not calculated correctly for one of the four students noted above. The incorrect number of days in the semester was used for the students. The remaining R2T4s calculated by the University were reviewed. Two additional R2T4s were not completed and Title IV funds were not returned timely. Criteria: Per the Student Financial Aid Handbook Volume 5, Chapter 2, “a school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. The number of days in the semester is calculated by counting the number of days in the semester less any breaks of four or more days. If a student does not begin attendance in a module course, the student is ineligible to receive Federal Pell Grant funds for that course. Those Federal Pell Grant funds are automatically returned to the Department of Education. The Federal Pell Grant funds must be recalculated based on the number of hours the student began attendance in. The adjusted Federal Pell Grant figure is used in the R2T4 calculation. Cause: The financial aid director was not always made aware when a student withdrew from the University. In addition, the third-party servicer was slow to process the R2T4 calculation and return the funds or make post-withdraw distributions. Federal Pell Grant funds were properly adjusted for a student who did not begin a module course and properly excluded from the R2T4 calculation, However, the Federal Pell Grant funds were not returned to the Department of Education. For the R2T4 that was miscalculated, the break days were not excluded from the number of days in the semester calculation due to a formula error in the Excel spreadsheet used to calculate the R2T4. Possible Asserted Effect: The following lists the effect for each of the six students associated with the finding: or the first student, the R2T4 was not completed timely, but was calculated correctly. The student is due a $1,849 Federal Pell Grant post withdraw disbursement that was not offered or disbursed. For the second student, the R2T4 was not completed timely and the funds were not returned timely. However, the funds were returned before the end of the award year. For the third student, the R2T4 was not completed timely, but was calculated correctly. The student is due a $862 Federal Pell Grant post withdraw disbursement that was not offered or disbursed. For the fourth student, the R2T4 was not completed timely and the incorrect number of days in the semester was used in the calculation. $4,527 of Unsubsidized Federal Direct Loans should be returned. For the fifth student, the R2T4 was not completed timely and the funds were not returned timely. The R2T4 was calculated correctly. $10,142 of Unsubsidized Federal Direct Loan funds was returned in September 2023.For the sixth student the R2T4 was not completed timely, but was calculated correctly. However, the $862 due to the Department of Education for a module that the student did not begin attendance in has yet to be returned. Repeat Finding: See Finding 2022-003 for a similar finding the prior year. Recommendation: Procedures and communication should be improved with the third-party servicer to ensure that the third-party servicer is given all of the information needed to complete the calculation and that the R2T4 calculation is completed and the funds are returned to the Department of Education timely. Post-withdraw distributions of $1,849 and $862 should be offered to two of the students in question. $862 of Federal Pell Grant funds should be returned to the Department of Education. The one R2T4 that was not calculated correctly should be recalculated and $4,527 of Unsubsidized Federal Direct Loan funds should be returned to the Department of Education. Management Response: Management agrees that all six R2T4s were completed late and funds were returned late or post-withdraw disbursements were not made timely. The Financial Aid Director will work with University officials to ensure that the Financial Aid Office is informed of enrollment status changes timely. The Financial Aid Director and the CFO will meet with the third-party administrator to resolve the amount of time it is taking for them to review and approve the R2T4s and return funds or award post-withdraw disbursements. The following monetary issues are in the process of being resolved: the first student identified above is due a $1,849 Federal Pell Grant post withdraw disbursement that was not offered or disbursed. $1,849 was posted to the student’s account on February 29, 2024. For the third student identified above, the R2T4 was sent to the third-party administrator for review in November 2023. The University has an ongoing audit being performed by the Department of Education. Based on advice from the University’s Department of Education contact, the resolution for this student should wait until the Department’s audit is complete. For the fourth student identified above, the R2T4 was not completed timely and the incorrect number of days in the semester was used in the calculation. A R2T4 was submitted to the third-party administrator in November 2023. On February 29, 2024, the student’s account show the following amounts were returned to the source: $990 of unsubsidized loan funds, $2,227 of subsidized loan funds, and $1,310 of PLUS Loan funds. For the sixth student identified above, the Student Financial Aid Director missed a notification from the third-party administrator asking for additional files. The information was supplied to the third-party administrator in November 2023. $862 was returned to the source on December 4, 2023.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($554,113) Award Number: P063P223315 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: $1,461 Condition Found: The amount of Pell grant awarded was calculated incorrectly for one of the nineteen students who received Pell in our sample. The student was awarded Pell grant funds as if the student was enrolled full-time for the fall and spring semesters when the student was only enrolled ¾ time in the fall and half-time in the spring. The Student Financial Aid Office caught the original error. $731 of Federal Pell Grant funds was returned to the Department of Education for the fall semester on March 1, 2023. The Student Financial Aid Director identified that $1,461 should be returned from the spring semester; however, the University has yet to the return the funds. Criteria: Federal Pell Grant eligibility is determined by the student’s expected family contribution (“EFC”), cost of attendance, and enrollment status. Cause: The financial aid office was not informed that the student withdrew from courses after enrollment was finalized. This decreased the enrollment status from full-time to ¾ time in the fall semester and full-time to half-time for the spring semester. Possible Asserted Effect: The student received $1,461 in Pell Grant funds that the student was ineligible to receive. Repeat Finding: There was not a similar finding for the year ended June 30, 2022. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The University should return $1,461 of Federal Pell Grant Funds to the Department of Education. Communication between the offices should be improved so that financial aid is made aware of enrollment status changes timely. In addition, the Student Financial Aid Director should monitor the third-party administrator and follow-up when returns are not completed timely. Management Response: $1,461 was returned to the source on December 4, 2023. Communication between the offices will be improved so that financial aid is made aware of enrollment status changes timely. In addition, the Student Financial Aid Director will monitor the third-party administrator and follow-up when returns are not completed timely.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($1,222,088) Award Number: P268K233315 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: $7,420 Condition Found: The University held excess cash of $7,420 from the Federal Direct Program for more than three days. Criteria: The University was placed on the Heightened Cash Monitoring Method II in May 2023. The University is not allowed to hold excess cash. However, excess cash was held for more than three days from the Federal Direct Loan Program. Cause: The third-party administrator posted a $10,142 Federal Direct Loan return of funds to COD for a student and a total of $2,722 Federal Direct Loans in disbursements to COD for another student. The third-party administrator never returned the $7,420 net of these two transactions to the Department of Education via G5. Three months of monthly Federal Direct Loan reconciliations failed to detect the error as well. Possible Asserted Effect: The University held $7,420 of excess cash. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend that the Student Financial Aid Director and CFO of the University meet with the third-party administrator to determine why the funds were not returned timely and how the monthly Federal Direct Loan reconciliations did not detect the error. $7,420 of Federal Direct Loan funds should be returned to the Department of Education. Management Response: The Student Financial Aid Director and CFO of the University will meet with the third-party administrator in during fiscal year 2024. The $7,420 of Federal Direct Loan program funds were returned on December 15, 2023.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($1,222,088) 84.063 ($554,113)M Award Number: P268K233315 P063P223315 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: $4,527 (84.268) $862 (84.063) Condition Found: The R2T4 calculation and Title IV funds were not returned or post-withdraw disbursements were not made timely for four of the twenty-seven students in the compliance testing sample. In addition, the R2T4 was not calculated correctly for one of the four students noted above. The incorrect number of days in the semester was used for the students. The remaining R2T4s calculated by the University were reviewed. Two additional R2T4s were not completed and Title IV funds were not returned timely. Criteria: Per the Student Financial Aid Handbook Volume 5, Chapter 2, “a school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. The number of days in the semester is calculated by counting the number of days in the semester less any breaks of four or more days. If a student does not begin attendance in a module course, the student is ineligible to receive Federal Pell Grant funds for that course. Those Federal Pell Grant funds are automatically returned to the Department of Education. The Federal Pell Grant funds must be recalculated based on the number of hours the student began attendance in. The adjusted Federal Pell Grant figure is used in the R2T4 calculation. Cause: The financial aid director was not always made aware when a student withdrew from the University. In addition, the third-party servicer was slow to process the R2T4 calculation and return the funds or make post-withdraw distributions. Federal Pell Grant funds were properly adjusted for a student who did not begin a module course and properly excluded from the R2T4 calculation, However, the Federal Pell Grant funds were not returned to the Department of Education. For the R2T4 that was miscalculated, the break days were not excluded from the number of days in the semester calculation due to a formula error in the Excel spreadsheet used to calculate the R2T4. Possible Asserted Effect: The following lists the effect for each of the six students associated with the finding: or the first student, the R2T4 was not completed timely, but was calculated correctly. The student is due a $1,849 Federal Pell Grant post withdraw disbursement that was not offered or disbursed. For the second student, the R2T4 was not completed timely and the funds were not returned timely. However, the funds were returned before the end of the award year. For the third student, the R2T4 was not completed timely, but was calculated correctly. The student is due a $862 Federal Pell Grant post withdraw disbursement that was not offered or disbursed. For the fourth student, the R2T4 was not completed timely and the incorrect number of days in the semester was used in the calculation. $4,527 of Unsubsidized Federal Direct Loans should be returned. For the fifth student, the R2T4 was not completed timely and the funds were not returned timely. The R2T4 was calculated correctly. $10,142 of Unsubsidized Federal Direct Loan funds was returned in September 2023.For the sixth student the R2T4 was not completed timely, but was calculated correctly. However, the $862 due to the Department of Education for a module that the student did not begin attendance in has yet to be returned. Repeat Finding: See Finding 2022-003 for a similar finding the prior year. Recommendation: Procedures and communication should be improved with the third-party servicer to ensure that the third-party servicer is given all of the information needed to complete the calculation and that the R2T4 calculation is completed and the funds are returned to the Department of Education timely. Post-withdraw distributions of $1,849 and $862 should be offered to two of the students in question. $862 of Federal Pell Grant funds should be returned to the Department of Education. The one R2T4 that was not calculated correctly should be recalculated and $4,527 of Unsubsidized Federal Direct Loan funds should be returned to the Department of Education. Management Response: Management agrees that all six R2T4s were completed late and funds were returned late or post-withdraw disbursements were not made timely. The Financial Aid Director will work with University officials to ensure that the Financial Aid Office is informed of enrollment status changes timely. The Financial Aid Director and the CFO will meet with the third-party administrator to resolve the amount of time it is taking for them to review and approve the R2T4s and return funds or award post-withdraw disbursements. The following monetary issues are in the process of being resolved: the first student identified above is due a $1,849 Federal Pell Grant post withdraw disbursement that was not offered or disbursed. $1,849 was posted to the student’s account on February 29, 2024. For the third student identified above, the R2T4 was sent to the third-party administrator for review in November 2023. The University has an ongoing audit being performed by the Department of Education. Based on advice from the University’s Department of Education contact, the resolution for this student should wait until the Department’s audit is complete. For the fourth student identified above, the R2T4 was not completed timely and the incorrect number of days in the semester was used in the calculation. A R2T4 was submitted to the third-party administrator in November 2023. On February 29, 2024, the student’s account show the following amounts were returned to the source: $990 of unsubsidized loan funds, $2,227 of subsidized loan funds, and $1,310 of PLUS Loan funds. For the sixth student identified above, the Student Financial Aid Director missed a notification from the third-party administrator asking for additional files. The information was supplied to the third-party administrator in November 2023. $862 was returned to the source on December 4, 2023.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($1,222,088) Award Number: P268K233315 and P26K223315 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: $-0- Condition Found: The incorrect enrollment status was reported to the National Student Loan Database System (“NSLDS”) for fourteen of the twenty-seven students selected for testing. Criteria: NSLDS informs loan servicers of changes in a student’s enrollment status that indicates when the repayments or interest accrual begins and ends. The date a student enrolls, withdraws, graduates, or drops below half-time status should be reported accurately. Cause: The University began working with a new third-party servicer in fiscal year 2021. The University was responsible for reporting enrollment status changes to the third-party servicer, and the third-party servicer was responsible for updating NSLDS. This process still continued to take longer than anticipated during fiscal year 2023. Possible Asserted Effect: The loan servicers were not aware of the correct deferral, repayment, and interest calculation dates. Repeat Finding: See Finding 2022-005 for a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Student Financial Aid Director should work with the third-party servicer to update the enrollment status of the eleven affected students in NSLDS. In addition, we recommend determining the amount of time the third-party servicer needs to process enrollment status changes. The University should make any necessary changes to its procedures or timeline for reporting enrollment status changes. Management Response: The Student Financial Aid Director corrected the enrollment status and withdrawal date for the students in question in November 2023. Procedures have been improved to ensure the information is communicated timely to the third-party servicer and that third-party servicer reports the changes to NSLDS timely.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($1,222,088) 84.063 ($554,113)M Award Number: P268K233315 P063P223315 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: $4,527 (84.268) $862 (84.063) Condition Found: The R2T4 calculation and Title IV funds were not returned or post-withdraw disbursements were not made timely for four of the twenty-seven students in the compliance testing sample. In addition, the R2T4 was not calculated correctly for one of the four students noted above. The incorrect number of days in the semester was used for the students. The remaining R2T4s calculated by the University were reviewed. Two additional R2T4s were not completed and Title IV funds were not returned timely. Criteria: Per the Student Financial Aid Handbook Volume 5, Chapter 2, “a school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. The number of days in the semester is calculated by counting the number of days in the semester less any breaks of four or more days. If a student does not begin attendance in a module course, the student is ineligible to receive Federal Pell Grant funds for that course. Those Federal Pell Grant funds are automatically returned to the Department of Education. The Federal Pell Grant funds must be recalculated based on the number of hours the student began attendance in. The adjusted Federal Pell Grant figure is used in the R2T4 calculation. Cause: The financial aid director was not always made aware when a student withdrew from the University. In addition, the third-party servicer was slow to process the R2T4 calculation and return the funds or make post-withdraw distributions. Federal Pell Grant funds were properly adjusted for a student who did not begin a module course and properly excluded from the R2T4 calculation, However, the Federal Pell Grant funds were not returned to the Department of Education. For the R2T4 that was miscalculated, the break days were not excluded from the number of days in the semester calculation due to a formula error in the Excel spreadsheet used to calculate the R2T4. Possible Asserted Effect: The following lists the effect for each of the six students associated with the finding: or the first student, the R2T4 was not completed timely, but was calculated correctly. The student is due a $1,849 Federal Pell Grant post withdraw disbursement that was not offered or disbursed. For the second student, the R2T4 was not completed timely and the funds were not returned timely. However, the funds were returned before the end of the award year. For the third student, the R2T4 was not completed timely, but was calculated correctly. The student is due a $862 Federal Pell Grant post withdraw disbursement that was not offered or disbursed. For the fourth student, the R2T4 was not completed timely and the incorrect number of days in the semester was used in the calculation. $4,527 of Unsubsidized Federal Direct Loans should be returned. For the fifth student, the R2T4 was not completed timely and the funds were not returned timely. The R2T4 was calculated correctly. $10,142 of Unsubsidized Federal Direct Loan funds was returned in September 2023.For the sixth student the R2T4 was not completed timely, but was calculated correctly. However, the $862 due to the Department of Education for a module that the student did not begin attendance in has yet to be returned. Repeat Finding: See Finding 2022-003 for a similar finding the prior year. Recommendation: Procedures and communication should be improved with the third-party servicer to ensure that the third-party servicer is given all of the information needed to complete the calculation and that the R2T4 calculation is completed and the funds are returned to the Department of Education timely. Post-withdraw distributions of $1,849 and $862 should be offered to two of the students in question. $862 of Federal Pell Grant funds should be returned to the Department of Education. The one R2T4 that was not calculated correctly should be recalculated and $4,527 of Unsubsidized Federal Direct Loan funds should be returned to the Department of Education. Management Response: Management agrees that all six R2T4s were completed late and funds were returned late or post-withdraw disbursements were not made timely. The Financial Aid Director will work with University officials to ensure that the Financial Aid Office is informed of enrollment status changes timely. The Financial Aid Director and the CFO will meet with the third-party administrator to resolve the amount of time it is taking for them to review and approve the R2T4s and return funds or award post-withdraw disbursements. The following monetary issues are in the process of being resolved: the first student identified above is due a $1,849 Federal Pell Grant post withdraw disbursement that was not offered or disbursed. $1,849 was posted to the student’s account on February 29, 2024. For the third student identified above, the R2T4 was sent to the third-party administrator for review in November 2023. The University has an ongoing audit being performed by the Department of Education. Based on advice from the University’s Department of Education contact, the resolution for this student should wait until the Department’s audit is complete. For the fourth student identified above, the R2T4 was not completed timely and the incorrect number of days in the semester was used in the calculation. A R2T4 was submitted to the third-party administrator in November 2023. On February 29, 2024, the student’s account show the following amounts were returned to the source: $990 of unsubsidized loan funds, $2,227 of subsidized loan funds, and $1,310 of PLUS Loan funds. For the sixth student identified above, the Student Financial Aid Director missed a notification from the third-party administrator asking for additional files. The information was supplied to the third-party administrator in November 2023. $862 was returned to the source on December 4, 2023.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($554,113) Award Number: P063P223315 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: $1,461 Condition Found: The amount of Pell grant awarded was calculated incorrectly for one of the nineteen students who received Pell in our sample. The student was awarded Pell grant funds as if the student was enrolled full-time for the fall and spring semesters when the student was only enrolled ¾ time in the fall and half-time in the spring. The Student Financial Aid Office caught the original error. $731 of Federal Pell Grant funds was returned to the Department of Education for the fall semester on March 1, 2023. The Student Financial Aid Director identified that $1,461 should be returned from the spring semester; however, the University has yet to the return the funds. Criteria: Federal Pell Grant eligibility is determined by the student’s expected family contribution (“EFC”), cost of attendance, and enrollment status. Cause: The financial aid office was not informed that the student withdrew from courses after enrollment was finalized. This decreased the enrollment status from full-time to ¾ time in the fall semester and full-time to half-time for the spring semester. Possible Asserted Effect: The student received $1,461 in Pell Grant funds that the student was ineligible to receive. Repeat Finding: There was not a similar finding for the year ended June 30, 2022. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The University should return $1,461 of Federal Pell Grant Funds to the Department of Education. Communication between the offices should be improved so that financial aid is made aware of enrollment status changes timely. In addition, the Student Financial Aid Director should monitor the third-party administrator and follow-up when returns are not completed timely. Management Response: $1,461 was returned to the source on December 4, 2023. Communication between the offices will be improved so that financial aid is made aware of enrollment status changes timely. In addition, the Student Financial Aid Director will monitor the third-party administrator and follow-up when returns are not completed timely.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($1,222,088) Award Number: P268K233315 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: $7,420 Condition Found: The University held excess cash of $7,420 from the Federal Direct Program for more than three days. Criteria: The University was placed on the Heightened Cash Monitoring Method II in May 2023. The University is not allowed to hold excess cash. However, excess cash was held for more than three days from the Federal Direct Loan Program. Cause: The third-party administrator posted a $10,142 Federal Direct Loan return of funds to COD for a student and a total of $2,722 Federal Direct Loans in disbursements to COD for another student. The third-party administrator never returned the $7,420 net of these two transactions to the Department of Education via G5. Three months of monthly Federal Direct Loan reconciliations failed to detect the error as well. Possible Asserted Effect: The University held $7,420 of excess cash. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend that the Student Financial Aid Director and CFO of the University meet with the third-party administrator to determine why the funds were not returned timely and how the monthly Federal Direct Loan reconciliations did not detect the error. $7,420 of Federal Direct Loan funds should be returned to the Department of Education. Management Response: The Student Financial Aid Director and CFO of the University will meet with the third-party administrator in during fiscal year 2024. The $7,420 of Federal Direct Loan program funds were returned on December 15, 2023.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($1,222,088) 84.063 ($554,113)M Award Number: P268K233315 P063P223315 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: $4,527 (84.268) $862 (84.063) Condition Found: The R2T4 calculation and Title IV funds were not returned or post-withdraw disbursements were not made timely for four of the twenty-seven students in the compliance testing sample. In addition, the R2T4 was not calculated correctly for one of the four students noted above. The incorrect number of days in the semester was used for the students. The remaining R2T4s calculated by the University were reviewed. Two additional R2T4s were not completed and Title IV funds were not returned timely. Criteria: Per the Student Financial Aid Handbook Volume 5, Chapter 2, “a school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. The number of days in the semester is calculated by counting the number of days in the semester less any breaks of four or more days. If a student does not begin attendance in a module course, the student is ineligible to receive Federal Pell Grant funds for that course. Those Federal Pell Grant funds are automatically returned to the Department of Education. The Federal Pell Grant funds must be recalculated based on the number of hours the student began attendance in. The adjusted Federal Pell Grant figure is used in the R2T4 calculation. Cause: The financial aid director was not always made aware when a student withdrew from the University. In addition, the third-party servicer was slow to process the R2T4 calculation and return the funds or make post-withdraw distributions. Federal Pell Grant funds were properly adjusted for a student who did not begin a module course and properly excluded from the R2T4 calculation, However, the Federal Pell Grant funds were not returned to the Department of Education. For the R2T4 that was miscalculated, the break days were not excluded from the number of days in the semester calculation due to a formula error in the Excel spreadsheet used to calculate the R2T4. Possible Asserted Effect: The following lists the effect for each of the six students associated with the finding: or the first student, the R2T4 was not completed timely, but was calculated correctly. The student is due a $1,849 Federal Pell Grant post withdraw disbursement that was not offered or disbursed. For the second student, the R2T4 was not completed timely and the funds were not returned timely. However, the funds were returned before the end of the award year. For the third student, the R2T4 was not completed timely, but was calculated correctly. The student is due a $862 Federal Pell Grant post withdraw disbursement that was not offered or disbursed. For the fourth student, the R2T4 was not completed timely and the incorrect number of days in the semester was used in the calculation. $4,527 of Unsubsidized Federal Direct Loans should be returned. For the fifth student, the R2T4 was not completed timely and the funds were not returned timely. The R2T4 was calculated correctly. $10,142 of Unsubsidized Federal Direct Loan funds was returned in September 2023.For the sixth student the R2T4 was not completed timely, but was calculated correctly. However, the $862 due to the Department of Education for a module that the student did not begin attendance in has yet to be returned. Repeat Finding: See Finding 2022-003 for a similar finding the prior year. Recommendation: Procedures and communication should be improved with the third-party servicer to ensure that the third-party servicer is given all of the information needed to complete the calculation and that the R2T4 calculation is completed and the funds are returned to the Department of Education timely. Post-withdraw distributions of $1,849 and $862 should be offered to two of the students in question. $862 of Federal Pell Grant funds should be returned to the Department of Education. The one R2T4 that was not calculated correctly should be recalculated and $4,527 of Unsubsidized Federal Direct Loan funds should be returned to the Department of Education. Management Response: Management agrees that all six R2T4s were completed late and funds were returned late or post-withdraw disbursements were not made timely. The Financial Aid Director will work with University officials to ensure that the Financial Aid Office is informed of enrollment status changes timely. The Financial Aid Director and the CFO will meet with the third-party administrator to resolve the amount of time it is taking for them to review and approve the R2T4s and return funds or award post-withdraw disbursements. The following monetary issues are in the process of being resolved: the first student identified above is due a $1,849 Federal Pell Grant post withdraw disbursement that was not offered or disbursed. $1,849 was posted to the student’s account on February 29, 2024. For the third student identified above, the R2T4 was sent to the third-party administrator for review in November 2023. The University has an ongoing audit being performed by the Department of Education. Based on advice from the University’s Department of Education contact, the resolution for this student should wait until the Department’s audit is complete. For the fourth student identified above, the R2T4 was not completed timely and the incorrect number of days in the semester was used in the calculation. A R2T4 was submitted to the third-party administrator in November 2023. On February 29, 2024, the student’s account show the following amounts were returned to the source: $990 of unsubsidized loan funds, $2,227 of subsidized loan funds, and $1,310 of PLUS Loan funds. For the sixth student identified above, the Student Financial Aid Director missed a notification from the third-party administrator asking for additional files. The information was supplied to the third-party administrator in November 2023. $862 was returned to the source on December 4, 2023.