2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA)
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act.
Questioned costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The University was not in Gramm-Leach-Bliley compliance standards.
Repeat finding: No.
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA)
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act.
Questioned costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The University was not in Gramm-Leach-Bliley compliance standards.
Repeat finding: No.
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA)
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act.
Questioned costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The University was not in Gramm-Leach-Bliley compliance standards.
Repeat finding: No.
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA)
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act.
Questioned costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The University was not in Gramm-Leach-Bliley compliance standards.
Repeat finding: No.
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA)
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act.
Questioned costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The University was not in Gramm-Leach-Bliley compliance standards.
Repeat finding: No.
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA)
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act.
Questioned costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The University was not in Gramm-Leach-Bliley compliance standards.
Repeat finding: No.
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Questioned costs: None.
Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement
Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students.
Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Questioned costs: None.
Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement
Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students.
Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Questioned costs: None.
Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement
Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students.
Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Questioned costs: None.
Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement
Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students.
Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Questioned costs: None.
Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement
Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students.
Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Questioned costs: None.
Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement
Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students.
Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly have documentation of exit counseling notification.
Questioned costs: None.
Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification.
Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No.
Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly have documentation of exit counseling notification.
Questioned costs: None.
Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification.
Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No.
Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly have documentation of exit counseling notification.
Questioned costs: None.
Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification.
Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No.
Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly have documentation of exit counseling notification.
Questioned costs: None.
Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification.
Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No.
Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly have documentation of exit counseling notification.
Questioned costs: None.
Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification.
Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No.
Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly have documentation of exit counseling notification.
Questioned costs: None.
Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification.
Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No.
Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Questioned costs: None.
Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Cause: Due to staff turnover, direct loan reconciliations were not maintained.
Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management.
Repeat finding: No.
Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Questioned costs: None.
Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Cause: Due to staff turnover, direct loan reconciliations were not maintained.
Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management.
Repeat finding: No.
Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Questioned costs: None.
Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Cause: Due to staff turnover, direct loan reconciliations were not maintained.
Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management.
Repeat finding: No.
Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Questioned costs: None.
Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Cause: Due to staff turnover, direct loan reconciliations were not maintained.
Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management.
Repeat finding: No.
Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Questioned costs: None.
Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Cause: Due to staff turnover, direct loan reconciliations were not maintained.
Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management.
Repeat finding: No.
Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Questioned costs: None.
Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Cause: Due to staff turnover, direct loan reconciliations were not maintained.
Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management.
Repeat finding: No.
Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023
Questioned costs: None.
Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days.
Cause: Due to staff turnover, stale checks were not being monitored.
Effect: Funds are not returned to the Department of Education in a timely manner
Repeat finding: No.
Recommendation: We recommend that the University review processes to track Title IV refund checks
Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023
Questioned costs: None.
Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days.
Cause: Due to staff turnover, stale checks were not being monitored.
Effect: Funds are not returned to the Department of Education in a timely manner
Repeat finding: No.
Recommendation: We recommend that the University review processes to track Title IV refund checks
Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023
Questioned costs: None.
Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days.
Cause: Due to staff turnover, stale checks were not being monitored.
Effect: Funds are not returned to the Department of Education in a timely manner
Repeat finding: No.
Recommendation: We recommend that the University review processes to track Title IV refund checks
Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023
Questioned costs: None.
Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days.
Cause: Due to staff turnover, stale checks were not being monitored.
Effect: Funds are not returned to the Department of Education in a timely manner
Repeat finding: No.
Recommendation: We recommend that the University review processes to track Title IV refund checks
Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023
Questioned costs: None.
Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days.
Cause: Due to staff turnover, stale checks were not being monitored.
Effect: Funds are not returned to the Department of Education in a timely manner
Repeat finding: No.
Recommendation: We recommend that the University review processes to track Title IV refund checks
Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023
Questioned costs: None.
Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days.
Cause: Due to staff turnover, stale checks were not being monitored.
Effect: Funds are not returned to the Department of Education in a timely manner
Repeat finding: No.
Recommendation: We recommend that the University review processes to track Title IV refund checks
Views of responsible officials: There is no disagreement with the audit finding.
2023-008: Eligibility: Student Timesheets
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA Handbook, you must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle. These amounts and hours recorded must match the hours for which the student is paid.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not accurately pay Federal Work Study (FWS) funds based on hours reported on timesheet.
Questioned costs: None.
Context: During our testing of FWS, we identified one instance where a students hours reported did not match the hours the student was paid causing an overpayment.
Cause: Due to human error, hours were not removed properly before submitted to payroll.
Effect: If timesheets are not properly reported then inaccurate FWS funds could be disbursed.
Repeat finding: No.
Recommendation: We recommend the University review processes to complete and review timesheets for FWS students.
Views of responsible officials: There is no disagreement with the audit finding.
2023-008: Eligibility: Student Timesheets
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA Handbook, you must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle. These amounts and hours recorded must match the hours for which the student is paid.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not accurately pay Federal Work Study (FWS) funds based on hours reported on timesheet.
Questioned costs: None.
Context: During our testing of FWS, we identified one instance where a students hours reported did not match the hours the student was paid causing an overpayment.
Cause: Due to human error, hours were not removed properly before submitted to payroll.
Effect: If timesheets are not properly reported then inaccurate FWS funds could be disbursed.
Repeat finding: No.
Recommendation: We recommend the University review processes to complete and review timesheets for FWS students.
Views of responsible officials: There is no disagreement with the audit finding.
2023-008: Eligibility: Student Timesheets
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA Handbook, you must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle. These amounts and hours recorded must match the hours for which the student is paid.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not accurately pay Federal Work Study (FWS) funds based on hours reported on timesheet.
Questioned costs: None.
Context: During our testing of FWS, we identified one instance where a students hours reported did not match the hours the student was paid causing an overpayment.
Cause: Due to human error, hours were not removed properly before submitted to payroll.
Effect: If timesheets are not properly reported then inaccurate FWS funds could be disbursed.
Repeat finding: No.
Recommendation: We recommend the University review processes to complete and review timesheets for FWS students.
Views of responsible officials: There is no disagreement with the audit finding.
2023-008: Eligibility: Student Timesheets
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA Handbook, you must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle. These amounts and hours recorded must match the hours for which the student is paid.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not accurately pay Federal Work Study (FWS) funds based on hours reported on timesheet.
Questioned costs: None.
Context: During our testing of FWS, we identified one instance where a students hours reported did not match the hours the student was paid causing an overpayment.
Cause: Due to human error, hours were not removed properly before submitted to payroll.
Effect: If timesheets are not properly reported then inaccurate FWS funds could be disbursed.
Repeat finding: No.
Recommendation: We recommend the University review processes to complete and review timesheets for FWS students.
Views of responsible officials: There is no disagreement with the audit finding.
2023-008: Eligibility: Student Timesheets
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA Handbook, you must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle. These amounts and hours recorded must match the hours for which the student is paid.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not accurately pay Federal Work Study (FWS) funds based on hours reported on timesheet.
Questioned costs: None.
Context: During our testing of FWS, we identified one instance where a students hours reported did not match the hours the student was paid causing an overpayment.
Cause: Due to human error, hours were not removed properly before submitted to payroll.
Effect: If timesheets are not properly reported then inaccurate FWS funds could be disbursed.
Repeat finding: No.
Recommendation: We recommend the University review processes to complete and review timesheets for FWS students.
Views of responsible officials: There is no disagreement with the audit finding.
2023-008: Eligibility: Student Timesheets
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA Handbook, you must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle. These amounts and hours recorded must match the hours for which the student is paid.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not accurately pay Federal Work Study (FWS) funds based on hours reported on timesheet.
Questioned costs: None.
Context: During our testing of FWS, we identified one instance where a students hours reported did not match the hours the student was paid causing an overpayment.
Cause: Due to human error, hours were not removed properly before submitted to payroll.
Effect: If timesheets are not properly reported then inaccurate FWS funds could be disbursed.
Repeat finding: No.
Recommendation: We recommend the University review processes to complete and review timesheets for FWS students.
Views of responsible officials: There is no disagreement with the audit finding.
2023-009: Special Tests and Provisions: Enrollment Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly report student enrollment changes for one student who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 28 students, we identified 1 student had the incorrect effective date and was reported past the 60-day reporting timeframe.
Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student could have inaccurate loan status if their enrollment status is not changed timely.
Repeat finding: No.
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: There is no disagreement with the audit finding.
2023-009: Special Tests and Provisions: Enrollment Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly report student enrollment changes for one student who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 28 students, we identified 1 student had the incorrect effective date and was reported past the 60-day reporting timeframe.
Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student could have inaccurate loan status if their enrollment status is not changed timely.
Repeat finding: No.
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: There is no disagreement with the audit finding.
2023-009: Special Tests and Provisions: Enrollment Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly report student enrollment changes for one student who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 28 students, we identified 1 student had the incorrect effective date and was reported past the 60-day reporting timeframe.
Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student could have inaccurate loan status if their enrollment status is not changed timely.
Repeat finding: No.
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: There is no disagreement with the audit finding.
2023-009: Special Tests and Provisions: Enrollment Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly report student enrollment changes for one student who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 28 students, we identified 1 student had the incorrect effective date and was reported past the 60-day reporting timeframe.
Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student could have inaccurate loan status if their enrollment status is not changed timely.
Repeat finding: No.
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: There is no disagreement with the audit finding.
2023-009: Special Tests and Provisions: Enrollment Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly report student enrollment changes for one student who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 28 students, we identified 1 student had the incorrect effective date and was reported past the 60-day reporting timeframe.
Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student could have inaccurate loan status if their enrollment status is not changed timely.
Repeat finding: No.
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: There is no disagreement with the audit finding.
2023-009: Special Tests and Provisions: Enrollment Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly report student enrollment changes for one student who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 28 students, we identified 1 student had the incorrect effective date and was reported past the 60-day reporting timeframe.
Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student could have inaccurate loan status if their enrollment status is not changed timely.
Repeat finding: No.
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: There is no disagreement with the audit finding.
2023-010: Special Tests and Provisions: Return of Title IV Funds
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly evaluate unofficial withdrawals for the 2022-2023 aid year, correctly calculate returns or disburse return timely for Return to Title IV (R2T4) calculations. Additionally, the University did not have formal documentation of review for R2T4 calculations.
Questioned costs: $46,735
Context: During our testing of 8 R2T4s, we identified 1 instance of payment returned later than 45 days after the withdrawal was determined and 2 instances of award amounts being used instead of the net disbursed amount. Also during our testing we identified that unofficial withdrawals were not evaluated for the 2022-2023 aid year which resulted in 27 calculations to not be performed. Additionally, there was no documentation of review for R2T4 calculations.
Cause: Due to staff turnover, R2T4 calculations were not completed correctly or timely.
Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned.
Repeat finding: No.
Recommendation: We recommend the University review current processes for determining unofficial withdrawals and ensure calculations are performed correctly and returns disbursed timely. We also recommend the University document review of Return of Title IV calculations by an employee that did not prepare the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-010: Special Tests and Provisions: Return of Title IV Funds
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly evaluate unofficial withdrawals for the 2022-2023 aid year, correctly calculate returns or disburse return timely for Return to Title IV (R2T4) calculations. Additionally, the University did not have formal documentation of review for R2T4 calculations.
Questioned costs: $46,735
Context: During our testing of 8 R2T4s, we identified 1 instance of payment returned later than 45 days after the withdrawal was determined and 2 instances of award amounts being used instead of the net disbursed amount. Also during our testing we identified that unofficial withdrawals were not evaluated for the 2022-2023 aid year which resulted in 27 calculations to not be performed. Additionally, there was no documentation of review for R2T4 calculations.
Cause: Due to staff turnover, R2T4 calculations were not completed correctly or timely.
Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned.
Repeat finding: No.
Recommendation: We recommend the University review current processes for determining unofficial withdrawals and ensure calculations are performed correctly and returns disbursed timely. We also recommend the University document review of Return of Title IV calculations by an employee that did not prepare the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-010: Special Tests and Provisions: Return of Title IV Funds
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly evaluate unofficial withdrawals for the 2022-2023 aid year, correctly calculate returns or disburse return timely for Return to Title IV (R2T4) calculations. Additionally, the University did not have formal documentation of review for R2T4 calculations.
Questioned costs: $46,735
Context: During our testing of 8 R2T4s, we identified 1 instance of payment returned later than 45 days after the withdrawal was determined and 2 instances of award amounts being used instead of the net disbursed amount. Also during our testing we identified that unofficial withdrawals were not evaluated for the 2022-2023 aid year which resulted in 27 calculations to not be performed. Additionally, there was no documentation of review for R2T4 calculations.
Cause: Due to staff turnover, R2T4 calculations were not completed correctly or timely.
Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned.
Repeat finding: No.
Recommendation: We recommend the University review current processes for determining unofficial withdrawals and ensure calculations are performed correctly and returns disbursed timely. We also recommend the University document review of Return of Title IV calculations by an employee that did not prepare the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-010: Special Tests and Provisions: Return of Title IV Funds
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly evaluate unofficial withdrawals for the 2022-2023 aid year, correctly calculate returns or disburse return timely for Return to Title IV (R2T4) calculations. Additionally, the University did not have formal documentation of review for R2T4 calculations.
Questioned costs: $46,735
Context: During our testing of 8 R2T4s, we identified 1 instance of payment returned later than 45 days after the withdrawal was determined and 2 instances of award amounts being used instead of the net disbursed amount. Also during our testing we identified that unofficial withdrawals were not evaluated for the 2022-2023 aid year which resulted in 27 calculations to not be performed. Additionally, there was no documentation of review for R2T4 calculations.
Cause: Due to staff turnover, R2T4 calculations were not completed correctly or timely.
Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned.
Repeat finding: No.
Recommendation: We recommend the University review current processes for determining unofficial withdrawals and ensure calculations are performed correctly and returns disbursed timely. We also recommend the University document review of Return of Title IV calculations by an employee that did not prepare the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-010: Special Tests and Provisions: Return of Title IV Funds
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly evaluate unofficial withdrawals for the 2022-2023 aid year, correctly calculate returns or disburse return timely for Return to Title IV (R2T4) calculations. Additionally, the University did not have formal documentation of review for R2T4 calculations.
Questioned costs: $46,735
Context: During our testing of 8 R2T4s, we identified 1 instance of payment returned later than 45 days after the withdrawal was determined and 2 instances of award amounts being used instead of the net disbursed amount. Also during our testing we identified that unofficial withdrawals were not evaluated for the 2022-2023 aid year which resulted in 27 calculations to not be performed. Additionally, there was no documentation of review for R2T4 calculations.
Cause: Due to staff turnover, R2T4 calculations were not completed correctly or timely.
Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned.
Repeat finding: No.
Recommendation: We recommend the University review current processes for determining unofficial withdrawals and ensure calculations are performed correctly and returns disbursed timely. We also recommend the University document review of Return of Title IV calculations by an employee that did not prepare the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-010: Special Tests and Provisions: Return of Title IV Funds
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly evaluate unofficial withdrawals for the 2022-2023 aid year, correctly calculate returns or disburse return timely for Return to Title IV (R2T4) calculations. Additionally, the University did not have formal documentation of review for R2T4 calculations.
Questioned costs: $46,735
Context: During our testing of 8 R2T4s, we identified 1 instance of payment returned later than 45 days after the withdrawal was determined and 2 instances of award amounts being used instead of the net disbursed amount. Also during our testing we identified that unofficial withdrawals were not evaluated for the 2022-2023 aid year which resulted in 27 calculations to not be performed. Additionally, there was no documentation of review for R2T4 calculations.
Cause: Due to staff turnover, R2T4 calculations were not completed correctly or timely.
Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned.
Repeat finding: No.
Recommendation: We recommend the University review current processes for determining unofficial withdrawals and ensure calculations are performed correctly and returns disbursed timely. We also recommend the University document review of Return of Title IV calculations by an employee that did not prepare the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-011: Special Tests and Provisions: Third Party Servicers
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA handbook, when a school uses a third party servicer under a Tier One Agreement with processing direct payments of Title IV funds on behalf of the school, then a school must conduct reasonable due diligence reviews every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not meet the minimum requirements when in a Tier One Agreement with a third party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the University.
Questioned costs: None.
Context: During our testing of the third party agreement with Bank Mobile, we identified that the University did not conduct a due diligence review in the 2 year required timeframe.
Cause: Due to staff turnover, compliance requirements were not timely monitored.
Effect: The University was not in compliance with the using a servicer to deliver Title IV credit balances standards.
Repeat finding: No.
Recommendation: We recommend the University review current processes to ensure all compliance requirements are being met when using a third party servicer to deliver Title IV credit balances.
Views of responsible officials: There is no disagreement with the audit finding.
2023-011: Special Tests and Provisions: Third Party Servicers
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA handbook, when a school uses a third party servicer under a Tier One Agreement with processing direct payments of Title IV funds on behalf of the school, then a school must conduct reasonable due diligence reviews every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not meet the minimum requirements when in a Tier One Agreement with a third party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the University.
Questioned costs: None.
Context: During our testing of the third party agreement with Bank Mobile, we identified that the University did not conduct a due diligence review in the 2 year required timeframe.
Cause: Due to staff turnover, compliance requirements were not timely monitored.
Effect: The University was not in compliance with the using a servicer to deliver Title IV credit balances standards.
Repeat finding: No.
Recommendation: We recommend the University review current processes to ensure all compliance requirements are being met when using a third party servicer to deliver Title IV credit balances.
Views of responsible officials: There is no disagreement with the audit finding.
2023-011: Special Tests and Provisions: Third Party Servicers
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA handbook, when a school uses a third party servicer under a Tier One Agreement with processing direct payments of Title IV funds on behalf of the school, then a school must conduct reasonable due diligence reviews every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not meet the minimum requirements when in a Tier One Agreement with a third party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the University.
Questioned costs: None.
Context: During our testing of the third party agreement with Bank Mobile, we identified that the University did not conduct a due diligence review in the 2 year required timeframe.
Cause: Due to staff turnover, compliance requirements were not timely monitored.
Effect: The University was not in compliance with the using a servicer to deliver Title IV credit balances standards.
Repeat finding: No.
Recommendation: We recommend the University review current processes to ensure all compliance requirements are being met when using a third party servicer to deliver Title IV credit balances.
Views of responsible officials: There is no disagreement with the audit finding.
2023-011: Special Tests and Provisions: Third Party Servicers
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA handbook, when a school uses a third party servicer under a Tier One Agreement with processing direct payments of Title IV funds on behalf of the school, then a school must conduct reasonable due diligence reviews every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not meet the minimum requirements when in a Tier One Agreement with a third party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the University.
Questioned costs: None.
Context: During our testing of the third party agreement with Bank Mobile, we identified that the University did not conduct a due diligence review in the 2 year required timeframe.
Cause: Due to staff turnover, compliance requirements were not timely monitored.
Effect: The University was not in compliance with the using a servicer to deliver Title IV credit balances standards.
Repeat finding: No.
Recommendation: We recommend the University review current processes to ensure all compliance requirements are being met when using a third party servicer to deliver Title IV credit balances.
Views of responsible officials: There is no disagreement with the audit finding.
2023-011: Special Tests and Provisions: Third Party Servicers
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA handbook, when a school uses a third party servicer under a Tier One Agreement with processing direct payments of Title IV funds on behalf of the school, then a school must conduct reasonable due diligence reviews every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not meet the minimum requirements when in a Tier One Agreement with a third party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the University.
Questioned costs: None.
Context: During our testing of the third party agreement with Bank Mobile, we identified that the University did not conduct a due diligence review in the 2 year required timeframe.
Cause: Due to staff turnover, compliance requirements were not timely monitored.
Effect: The University was not in compliance with the using a servicer to deliver Title IV credit balances standards.
Repeat finding: No.
Recommendation: We recommend the University review current processes to ensure all compliance requirements are being met when using a third party servicer to deliver Title IV credit balances.
Views of responsible officials: There is no disagreement with the audit finding.
2023-011: Special Tests and Provisions: Third Party Servicers
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA handbook, when a school uses a third party servicer under a Tier One Agreement with processing direct payments of Title IV funds on behalf of the school, then a school must conduct reasonable due diligence reviews every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not meet the minimum requirements when in a Tier One Agreement with a third party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the University.
Questioned costs: None.
Context: During our testing of the third party agreement with Bank Mobile, we identified that the University did not conduct a due diligence review in the 2 year required timeframe.
Cause: Due to staff turnover, compliance requirements were not timely monitored.
Effect: The University was not in compliance with the using a servicer to deliver Title IV credit balances standards.
Repeat finding: No.
Recommendation: We recommend the University review current processes to ensure all compliance requirements are being met when using a third party servicer to deliver Title IV credit balances.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA)
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act.
Questioned costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The University was not in Gramm-Leach-Bliley compliance standards.
Repeat finding: No.
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA)
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act.
Questioned costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The University was not in Gramm-Leach-Bliley compliance standards.
Repeat finding: No.
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA)
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act.
Questioned costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The University was not in Gramm-Leach-Bliley compliance standards.
Repeat finding: No.
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA)
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act.
Questioned costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The University was not in Gramm-Leach-Bliley compliance standards.
Repeat finding: No.
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA)
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act.
Questioned costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The University was not in Gramm-Leach-Bliley compliance standards.
Repeat finding: No.
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 002: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA)
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act.
Questioned costs: None.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The University was not in Gramm-Leach-Bliley compliance standards.
Repeat finding: No.
Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Questioned costs: None.
Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement
Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students.
Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Questioned costs: None.
Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement
Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students.
Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Questioned costs: None.
Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement
Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students.
Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Questioned costs: None.
Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement
Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students.
Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Questioned costs: None.
Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement
Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students.
Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003: Eligibility: Loan Notifications
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly notify students when loans were credited to the student's ledger account.
Questioned costs: None.
Context: During our Eligibility testing of 40 students, we identified that there were 38 students that received loan disbursements however, 28 students did not receive the required notification for the Fall 2022 term loan disbursement
Cause: Due to staff turnover, Fall 2022 loan notifications were not sent to students.
Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly have documentation of exit counseling notification.
Questioned costs: None.
Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification.
Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No.
Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly have documentation of exit counseling notification.
Questioned costs: None.
Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification.
Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No.
Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly have documentation of exit counseling notification.
Questioned costs: None.
Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification.
Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No.
Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly have documentation of exit counseling notification.
Questioned costs: None.
Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification.
Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No.
Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly have documentation of exit counseling notification.
Questioned costs: None.
Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification.
Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No.
Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of responsible officials: There is no disagreement with the audit finding.
2023-004: Eligibility: Exit Counseling
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly have documentation of exit counseling notification.
Questioned costs: None.
Context: During our testing of 40 students, we identified 6 students that did not have documentation of exit counseling notification.
Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No.
Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Questioned costs: None.
Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Cause: Due to staff turnover, direct loan reconciliations were not maintained.
Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management.
Repeat finding: No.
Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Questioned costs: None.
Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Cause: Due to staff turnover, direct loan reconciliations were not maintained.
Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management.
Repeat finding: No.
Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Questioned costs: None.
Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Cause: Due to staff turnover, direct loan reconciliations were not maintained.
Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management.
Repeat finding: No.
Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Questioned costs: None.
Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Cause: Due to staff turnover, direct loan reconciliations were not maintained.
Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management.
Repeat finding: No.
Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Questioned costs: None.
Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Cause: Due to staff turnover, direct loan reconciliations were not maintained.
Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management.
Repeat finding: No.
Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of responsible officials: There is no disagreement with the audit finding.
2023-006: Reporting: Direct Loan Reconciliations
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by a University participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. A University must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Criteria or specific requirement (continued): Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Questioned costs: None.
Context: The University’s student financial aid department did not maintain documentation that monthly direct loan reconciliations were performed or reviewed.
Cause: Due to staff turnover, direct loan reconciliations were not maintained.
Effect: The lack of documented review of the direct loan reconciliations being performed by student financial aid department could result in errors in the reconciliation going undetected by student financial aid management.
Repeat finding: No.
Recommendation: We recommend the University implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023
Questioned costs: None.
Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days.
Cause: Due to staff turnover, stale checks were not being monitored.
Effect: Funds are not returned to the Department of Education in a timely manner
Repeat finding: No.
Recommendation: We recommend that the University review processes to track Title IV refund checks
Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023
Questioned costs: None.
Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days.
Cause: Due to staff turnover, stale checks were not being monitored.
Effect: Funds are not returned to the Department of Education in a timely manner
Repeat finding: No.
Recommendation: We recommend that the University review processes to track Title IV refund checks
Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023
Questioned costs: None.
Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days.
Cause: Due to staff turnover, stale checks were not being monitored.
Effect: Funds are not returned to the Department of Education in a timely manner
Repeat finding: No.
Recommendation: We recommend that the University review processes to track Title IV refund checks
Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023
Questioned costs: None.
Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days.
Cause: Due to staff turnover, stale checks were not being monitored.
Effect: Funds are not returned to the Department of Education in a timely manner
Repeat finding: No.
Recommendation: We recommend that the University review processes to track Title IV refund checks
Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023
Questioned costs: None.
Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days.
Cause: Due to staff turnover, stale checks were not being monitored.
Effect: Funds are not returned to the Department of Education in a timely manner
Repeat finding: No.
Recommendation: We recommend that the University review processes to track Title IV refund checks
Views of responsible officials: There is no disagreement with the audit finding.
2023-007: Special Tests and Provisions: Outstanding Checks over 240 Days
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University had 3 instances of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023
Questioned costs: None.
Context: During the testing of the outstanding Title IV student check listing CLA observed three instances of stale checks that were aged greater than 240 days.
Cause: Due to staff turnover, stale checks were not being monitored.
Effect: Funds are not returned to the Department of Education in a timely manner
Repeat finding: No.
Recommendation: We recommend that the University review processes to track Title IV refund checks
Views of responsible officials: There is no disagreement with the audit finding.
2023-008: Eligibility: Student Timesheets
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA Handbook, you must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle. These amounts and hours recorded must match the hours for which the student is paid.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not accurately pay Federal Work Study (FWS) funds based on hours reported on timesheet.
Questioned costs: None.
Context: During our testing of FWS, we identified one instance where a students hours reported did not match the hours the student was paid causing an overpayment.
Cause: Due to human error, hours were not removed properly before submitted to payroll.
Effect: If timesheets are not properly reported then inaccurate FWS funds could be disbursed.
Repeat finding: No.
Recommendation: We recommend the University review processes to complete and review timesheets for FWS students.
Views of responsible officials: There is no disagreement with the audit finding.
2023-008: Eligibility: Student Timesheets
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA Handbook, you must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle. These amounts and hours recorded must match the hours for which the student is paid.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not accurately pay Federal Work Study (FWS) funds based on hours reported on timesheet.
Questioned costs: None.
Context: During our testing of FWS, we identified one instance where a students hours reported did not match the hours the student was paid causing an overpayment.
Cause: Due to human error, hours were not removed properly before submitted to payroll.
Effect: If timesheets are not properly reported then inaccurate FWS funds could be disbursed.
Repeat finding: No.
Recommendation: We recommend the University review processes to complete and review timesheets for FWS students.
Views of responsible officials: There is no disagreement with the audit finding.
2023-008: Eligibility: Student Timesheets
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA Handbook, you must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle. These amounts and hours recorded must match the hours for which the student is paid.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not accurately pay Federal Work Study (FWS) funds based on hours reported on timesheet.
Questioned costs: None.
Context: During our testing of FWS, we identified one instance where a students hours reported did not match the hours the student was paid causing an overpayment.
Cause: Due to human error, hours were not removed properly before submitted to payroll.
Effect: If timesheets are not properly reported then inaccurate FWS funds could be disbursed.
Repeat finding: No.
Recommendation: We recommend the University review processes to complete and review timesheets for FWS students.
Views of responsible officials: There is no disagreement with the audit finding.
2023-008: Eligibility: Student Timesheets
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA Handbook, you must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle. These amounts and hours recorded must match the hours for which the student is paid.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not accurately pay Federal Work Study (FWS) funds based on hours reported on timesheet.
Questioned costs: None.
Context: During our testing of FWS, we identified one instance where a students hours reported did not match the hours the student was paid causing an overpayment.
Cause: Due to human error, hours were not removed properly before submitted to payroll.
Effect: If timesheets are not properly reported then inaccurate FWS funds could be disbursed.
Repeat finding: No.
Recommendation: We recommend the University review processes to complete and review timesheets for FWS students.
Views of responsible officials: There is no disagreement with the audit finding.
2023-008: Eligibility: Student Timesheets
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA Handbook, you must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle. These amounts and hours recorded must match the hours for which the student is paid.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not accurately pay Federal Work Study (FWS) funds based on hours reported on timesheet.
Questioned costs: None.
Context: During our testing of FWS, we identified one instance where a students hours reported did not match the hours the student was paid causing an overpayment.
Cause: Due to human error, hours were not removed properly before submitted to payroll.
Effect: If timesheets are not properly reported then inaccurate FWS funds could be disbursed.
Repeat finding: No.
Recommendation: We recommend the University review processes to complete and review timesheets for FWS students.
Views of responsible officials: There is no disagreement with the audit finding.
2023-008: Eligibility: Student Timesheets
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA Handbook, you must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle. These amounts and hours recorded must match the hours for which the student is paid.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not accurately pay Federal Work Study (FWS) funds based on hours reported on timesheet.
Questioned costs: None.
Context: During our testing of FWS, we identified one instance where a students hours reported did not match the hours the student was paid causing an overpayment.
Cause: Due to human error, hours were not removed properly before submitted to payroll.
Effect: If timesheets are not properly reported then inaccurate FWS funds could be disbursed.
Repeat finding: No.
Recommendation: We recommend the University review processes to complete and review timesheets for FWS students.
Views of responsible officials: There is no disagreement with the audit finding.
2023-009: Special Tests and Provisions: Enrollment Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly report student enrollment changes for one student who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 28 students, we identified 1 student had the incorrect effective date and was reported past the 60-day reporting timeframe.
Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student could have inaccurate loan status if their enrollment status is not changed timely.
Repeat finding: No.
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: There is no disagreement with the audit finding.
2023-009: Special Tests and Provisions: Enrollment Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly report student enrollment changes for one student who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 28 students, we identified 1 student had the incorrect effective date and was reported past the 60-day reporting timeframe.
Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student could have inaccurate loan status if their enrollment status is not changed timely.
Repeat finding: No.
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: There is no disagreement with the audit finding.
2023-009: Special Tests and Provisions: Enrollment Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly report student enrollment changes for one student who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 28 students, we identified 1 student had the incorrect effective date and was reported past the 60-day reporting timeframe.
Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student could have inaccurate loan status if their enrollment status is not changed timely.
Repeat finding: No.
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: There is no disagreement with the audit finding.
2023-009: Special Tests and Provisions: Enrollment Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly report student enrollment changes for one student who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 28 students, we identified 1 student had the incorrect effective date and was reported past the 60-day reporting timeframe.
Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student could have inaccurate loan status if their enrollment status is not changed timely.
Repeat finding: No.
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: There is no disagreement with the audit finding.
2023-009: Special Tests and Provisions: Enrollment Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly report student enrollment changes for one student who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 28 students, we identified 1 student had the incorrect effective date and was reported past the 60-day reporting timeframe.
Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student could have inaccurate loan status if their enrollment status is not changed timely.
Repeat finding: No.
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: There is no disagreement with the audit finding.
2023-009: Special Tests and Provisions: Enrollment Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly report student enrollment changes for one student who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 28 students, we identified 1 student had the incorrect effective date and was reported past the 60-day reporting timeframe.
Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student could have inaccurate loan status if their enrollment status is not changed timely.
Repeat finding: No.
Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: There is no disagreement with the audit finding.
2023-010: Special Tests and Provisions: Return of Title IV Funds
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly evaluate unofficial withdrawals for the 2022-2023 aid year, correctly calculate returns or disburse return timely for Return to Title IV (R2T4) calculations. Additionally, the University did not have formal documentation of review for R2T4 calculations.
Questioned costs: $46,735
Context: During our testing of 8 R2T4s, we identified 1 instance of payment returned later than 45 days after the withdrawal was determined and 2 instances of award amounts being used instead of the net disbursed amount. Also during our testing we identified that unofficial withdrawals were not evaluated for the 2022-2023 aid year which resulted in 27 calculations to not be performed. Additionally, there was no documentation of review for R2T4 calculations.
Cause: Due to staff turnover, R2T4 calculations were not completed correctly or timely.
Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned.
Repeat finding: No.
Recommendation: We recommend the University review current processes for determining unofficial withdrawals and ensure calculations are performed correctly and returns disbursed timely. We also recommend the University document review of Return of Title IV calculations by an employee that did not prepare the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-010: Special Tests and Provisions: Return of Title IV Funds
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly evaluate unofficial withdrawals for the 2022-2023 aid year, correctly calculate returns or disburse return timely for Return to Title IV (R2T4) calculations. Additionally, the University did not have formal documentation of review for R2T4 calculations.
Questioned costs: $46,735
Context: During our testing of 8 R2T4s, we identified 1 instance of payment returned later than 45 days after the withdrawal was determined and 2 instances of award amounts being used instead of the net disbursed amount. Also during our testing we identified that unofficial withdrawals were not evaluated for the 2022-2023 aid year which resulted in 27 calculations to not be performed. Additionally, there was no documentation of review for R2T4 calculations.
Cause: Due to staff turnover, R2T4 calculations were not completed correctly or timely.
Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned.
Repeat finding: No.
Recommendation: We recommend the University review current processes for determining unofficial withdrawals and ensure calculations are performed correctly and returns disbursed timely. We also recommend the University document review of Return of Title IV calculations by an employee that did not prepare the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-010: Special Tests and Provisions: Return of Title IV Funds
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly evaluate unofficial withdrawals for the 2022-2023 aid year, correctly calculate returns or disburse return timely for Return to Title IV (R2T4) calculations. Additionally, the University did not have formal documentation of review for R2T4 calculations.
Questioned costs: $46,735
Context: During our testing of 8 R2T4s, we identified 1 instance of payment returned later than 45 days after the withdrawal was determined and 2 instances of award amounts being used instead of the net disbursed amount. Also during our testing we identified that unofficial withdrawals were not evaluated for the 2022-2023 aid year which resulted in 27 calculations to not be performed. Additionally, there was no documentation of review for R2T4 calculations.
Cause: Due to staff turnover, R2T4 calculations were not completed correctly or timely.
Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned.
Repeat finding: No.
Recommendation: We recommend the University review current processes for determining unofficial withdrawals and ensure calculations are performed correctly and returns disbursed timely. We also recommend the University document review of Return of Title IV calculations by an employee that did not prepare the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-010: Special Tests and Provisions: Return of Title IV Funds
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly evaluate unofficial withdrawals for the 2022-2023 aid year, correctly calculate returns or disburse return timely for Return to Title IV (R2T4) calculations. Additionally, the University did not have formal documentation of review for R2T4 calculations.
Questioned costs: $46,735
Context: During our testing of 8 R2T4s, we identified 1 instance of payment returned later than 45 days after the withdrawal was determined and 2 instances of award amounts being used instead of the net disbursed amount. Also during our testing we identified that unofficial withdrawals were not evaluated for the 2022-2023 aid year which resulted in 27 calculations to not be performed. Additionally, there was no documentation of review for R2T4 calculations.
Cause: Due to staff turnover, R2T4 calculations were not completed correctly or timely.
Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned.
Repeat finding: No.
Recommendation: We recommend the University review current processes for determining unofficial withdrawals and ensure calculations are performed correctly and returns disbursed timely. We also recommend the University document review of Return of Title IV calculations by an employee that did not prepare the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-010: Special Tests and Provisions: Return of Title IV Funds
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly evaluate unofficial withdrawals for the 2022-2023 aid year, correctly calculate returns or disburse return timely for Return to Title IV (R2T4) calculations. Additionally, the University did not have formal documentation of review for R2T4 calculations.
Questioned costs: $46,735
Context: During our testing of 8 R2T4s, we identified 1 instance of payment returned later than 45 days after the withdrawal was determined and 2 instances of award amounts being used instead of the net disbursed amount. Also during our testing we identified that unofficial withdrawals were not evaluated for the 2022-2023 aid year which resulted in 27 calculations to not be performed. Additionally, there was no documentation of review for R2T4 calculations.
Cause: Due to staff turnover, R2T4 calculations were not completed correctly or timely.
Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned.
Repeat finding: No.
Recommendation: We recommend the University review current processes for determining unofficial withdrawals and ensure calculations are performed correctly and returns disbursed timely. We also recommend the University document review of Return of Title IV calculations by an employee that did not prepare the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-010: Special Tests and Provisions: Return of Title IV Funds
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not properly evaluate unofficial withdrawals for the 2022-2023 aid year, correctly calculate returns or disburse return timely for Return to Title IV (R2T4) calculations. Additionally, the University did not have formal documentation of review for R2T4 calculations.
Questioned costs: $46,735
Context: During our testing of 8 R2T4s, we identified 1 instance of payment returned later than 45 days after the withdrawal was determined and 2 instances of award amounts being used instead of the net disbursed amount. Also during our testing we identified that unofficial withdrawals were not evaluated for the 2022-2023 aid year which resulted in 27 calculations to not be performed. Additionally, there was no documentation of review for R2T4 calculations.
Cause: Due to staff turnover, R2T4 calculations were not completed correctly or timely.
Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned.
Repeat finding: No.
Recommendation: We recommend the University review current processes for determining unofficial withdrawals and ensure calculations are performed correctly and returns disbursed timely. We also recommend the University document review of Return of Title IV calculations by an employee that did not prepare the calculations.
Views of responsible officials: There is no disagreement with the audit finding.
2023-011: Special Tests and Provisions: Third Party Servicers
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA handbook, when a school uses a third party servicer under a Tier One Agreement with processing direct payments of Title IV funds on behalf of the school, then a school must conduct reasonable due diligence reviews every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not meet the minimum requirements when in a Tier One Agreement with a third party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the University.
Questioned costs: None.
Context: During our testing of the third party agreement with Bank Mobile, we identified that the University did not conduct a due diligence review in the 2 year required timeframe.
Cause: Due to staff turnover, compliance requirements were not timely monitored.
Effect: The University was not in compliance with the using a servicer to deliver Title IV credit balances standards.
Repeat finding: No.
Recommendation: We recommend the University review current processes to ensure all compliance requirements are being met when using a third party servicer to deliver Title IV credit balances.
Views of responsible officials: There is no disagreement with the audit finding.
2023-011: Special Tests and Provisions: Third Party Servicers
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA handbook, when a school uses a third party servicer under a Tier One Agreement with processing direct payments of Title IV funds on behalf of the school, then a school must conduct reasonable due diligence reviews every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not meet the minimum requirements when in a Tier One Agreement with a third party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the University.
Questioned costs: None.
Context: During our testing of the third party agreement with Bank Mobile, we identified that the University did not conduct a due diligence review in the 2 year required timeframe.
Cause: Due to staff turnover, compliance requirements were not timely monitored.
Effect: The University was not in compliance with the using a servicer to deliver Title IV credit balances standards.
Repeat finding: No.
Recommendation: We recommend the University review current processes to ensure all compliance requirements are being met when using a third party servicer to deliver Title IV credit balances.
Views of responsible officials: There is no disagreement with the audit finding.
2023-011: Special Tests and Provisions: Third Party Servicers
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA handbook, when a school uses a third party servicer under a Tier One Agreement with processing direct payments of Title IV funds on behalf of the school, then a school must conduct reasonable due diligence reviews every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not meet the minimum requirements when in a Tier One Agreement with a third party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the University.
Questioned costs: None.
Context: During our testing of the third party agreement with Bank Mobile, we identified that the University did not conduct a due diligence review in the 2 year required timeframe.
Cause: Due to staff turnover, compliance requirements were not timely monitored.
Effect: The University was not in compliance with the using a servicer to deliver Title IV credit balances standards.
Repeat finding: No.
Recommendation: We recommend the University review current processes to ensure all compliance requirements are being met when using a third party servicer to deliver Title IV credit balances.
Views of responsible officials: There is no disagreement with the audit finding.
2023-011: Special Tests and Provisions: Third Party Servicers
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA handbook, when a school uses a third party servicer under a Tier One Agreement with processing direct payments of Title IV funds on behalf of the school, then a school must conduct reasonable due diligence reviews every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not meet the minimum requirements when in a Tier One Agreement with a third party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the University.
Questioned costs: None.
Context: During our testing of the third party agreement with Bank Mobile, we identified that the University did not conduct a due diligence review in the 2 year required timeframe.
Cause: Due to staff turnover, compliance requirements were not timely monitored.
Effect: The University was not in compliance with the using a servicer to deliver Title IV credit balances standards.
Repeat finding: No.
Recommendation: We recommend the University review current processes to ensure all compliance requirements are being met when using a third party servicer to deliver Title IV credit balances.
Views of responsible officials: There is no disagreement with the audit finding.
2023-011: Special Tests and Provisions: Third Party Servicers
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA handbook, when a school uses a third party servicer under a Tier One Agreement with processing direct payments of Title IV funds on behalf of the school, then a school must conduct reasonable due diligence reviews every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not meet the minimum requirements when in a Tier One Agreement with a third party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the University.
Questioned costs: None.
Context: During our testing of the third party agreement with Bank Mobile, we identified that the University did not conduct a due diligence review in the 2 year required timeframe.
Cause: Due to staff turnover, compliance requirements were not timely monitored.
Effect: The University was not in compliance with the using a servicer to deliver Title IV credit balances standards.
Repeat finding: No.
Recommendation: We recommend the University review current processes to ensure all compliance requirements are being met when using a third party servicer to deliver Title IV credit balances.
Views of responsible officials: There is no disagreement with the audit finding.
2023-011: Special Tests and Provisions: Third Party Servicers
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per FSA handbook, when a school uses a third party servicer under a Tier One Agreement with processing direct payments of Title IV funds on behalf of the school, then a school must conduct reasonable due diligence reviews every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not meet the minimum requirements when in a Tier One Agreement with a third party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the University.
Questioned costs: None.
Context: During our testing of the third party agreement with Bank Mobile, we identified that the University did not conduct a due diligence review in the 2 year required timeframe.
Cause: Due to staff turnover, compliance requirements were not timely monitored.
Effect: The University was not in compliance with the using a servicer to deliver Title IV credit balances standards.
Repeat finding: No.
Recommendation: We recommend the University review current processes to ensure all compliance requirements are being met when using a third party servicer to deliver Title IV credit balances.
Views of responsible officials: There is no disagreement with the audit finding.