Finding 2023-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268
Compliance Requirement: Special Test and Provisions – Enrollment Reporting
Condition: The University is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change.
Criteria: The University is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change.
Cause: The University had not reported changes of withdrawn students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2023. The status information reported in the University’s system, Jenzabar (withdrawal date and last date of academic activity), was incorrectly extracted for the submission to the National Student Clearinghouse and NSLDS, which created discrepancies between the statuses. The University was unaware of this technical issue and did not have another monitoring mechanism in place that would have alerted them to this deficiency in the system reporting.
Context: The University did not send status changes related to seven withdrawn students, had four incorrect status effective dates, and sent two changes related to withdrawn students to the National Student Loan Data System (“NSLDS”) with incorrect effective dates and after 60 days. Nine of the thirteen findings occurred during the paused data reporting period of July 20, 2022 through February 28, 2023 as stated within the 2023 Compliance Supplement.
Effect: The University did not report withdraw changes to the NSLDS timely.
Recommendation: The University should put in place a process to timely capture withdrawn student changes so that they can be reported to the NSLDS.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2023-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268
Compliance Requirement: Special Test and Provisions – Enrollment Reporting
Condition: The University is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change.
Criteria: The University is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change.
Cause: The University had not reported changes of withdrawn students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2023. The status information reported in the University’s system, Jenzabar (withdrawal date and last date of academic activity), was incorrectly extracted for the submission to the National Student Clearinghouse and NSLDS, which created discrepancies between the statuses. The University was unaware of this technical issue and did not have another monitoring mechanism in place that would have alerted them to this deficiency in the system reporting.
Context: The University did not send status changes related to seven withdrawn students, had four incorrect status effective dates, and sent two changes related to withdrawn students to the National Student Loan Data System (“NSLDS”) with incorrect effective dates and after 60 days. Nine of the thirteen findings occurred during the paused data reporting period of July 20, 2022 through February 28, 2023 as stated within the 2023 Compliance Supplement.
Effect: The University did not report withdraw changes to the NSLDS timely.
Recommendation: The University should put in place a process to timely capture withdrawn student changes so that they can be reported to the NSLDS.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2023-003 – U.S. Department of Agriculture – Community Facilities Loan and Grant, CFDA# 10.766
Compliance Requirement: Other Information
Condition: U.S. Department of Agriculture (“USDA”) covenants and requirements were not adhered to.
Criteria: Borrowers are required to fund reserves, maintain insurance, deposit funds in Federally insured banks, meet financial covenants, maintain sufficient debt service ratios, and in some cases comply with additional requirements established as part of the loan approval process. These requirements indicate the continuing compliance requirements that borrowers must meet.
Cause: The University had turnover in the business department and non-quantitative requirements were not closely monitored.
Context: The University was not able to meet covenants during the year but obtained a covenant waiver through fiscal year 2024. Additionally, the University did not meet the all the requirements per the USDA loan agreement dated as of December 16, 2021. The following requirements were not met during the fiscal year ended June 30, 2023:
1. Internally produced financial statements within 45 days (Article V, 5.8 (b))
2. Compliance certificate (Article V, 5.8 (c))
3. Budget provided 30 days prior to the beginning of the new fiscal year (Article V, 5.8 (d))
4. Student housing rent roll (Article V, 5.16)
Effect: Lack of compliance with loan covenants and requirements.
Recommendation: The University’s management should read and follow all USDA loan covenants and requirements.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2023-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268
Compliance Requirement: Special Test and Provisions – Enrollment Reporting
Condition: The University is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change.
Criteria: The University is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change.
Cause: The University had not reported changes of withdrawn students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2023. The status information reported in the University’s system, Jenzabar (withdrawal date and last date of academic activity), was incorrectly extracted for the submission to the National Student Clearinghouse and NSLDS, which created discrepancies between the statuses. The University was unaware of this technical issue and did not have another monitoring mechanism in place that would have alerted them to this deficiency in the system reporting.
Context: The University did not send status changes related to seven withdrawn students, had four incorrect status effective dates, and sent two changes related to withdrawn students to the National Student Loan Data System (“NSLDS”) with incorrect effective dates and after 60 days. Nine of the thirteen findings occurred during the paused data reporting period of July 20, 2022 through February 28, 2023 as stated within the 2023 Compliance Supplement.
Effect: The University did not report withdraw changes to the NSLDS timely.
Recommendation: The University should put in place a process to timely capture withdrawn student changes so that they can be reported to the NSLDS.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2023-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268
Compliance Requirement: Special Test and Provisions – Enrollment Reporting
Condition: The University is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change.
Criteria: The University is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change.
Cause: The University had not reported changes of withdrawn students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2023. The status information reported in the University’s system, Jenzabar (withdrawal date and last date of academic activity), was incorrectly extracted for the submission to the National Student Clearinghouse and NSLDS, which created discrepancies between the statuses. The University was unaware of this technical issue and did not have another monitoring mechanism in place that would have alerted them to this deficiency in the system reporting.
Context: The University did not send status changes related to seven withdrawn students, had four incorrect status effective dates, and sent two changes related to withdrawn students to the National Student Loan Data System (“NSLDS”) with incorrect effective dates and after 60 days. Nine of the thirteen findings occurred during the paused data reporting period of July 20, 2022 through February 28, 2023 as stated within the 2023 Compliance Supplement.
Effect: The University did not report withdraw changes to the NSLDS timely.
Recommendation: The University should put in place a process to timely capture withdrawn student changes so that they can be reported to the NSLDS.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2023-003 – U.S. Department of Agriculture – Community Facilities Loan and Grant, CFDA# 10.766
Compliance Requirement: Other Information
Condition: U.S. Department of Agriculture (“USDA”) covenants and requirements were not adhered to.
Criteria: Borrowers are required to fund reserves, maintain insurance, deposit funds in Federally insured banks, meet financial covenants, maintain sufficient debt service ratios, and in some cases comply with additional requirements established as part of the loan approval process. These requirements indicate the continuing compliance requirements that borrowers must meet.
Cause: The University had turnover in the business department and non-quantitative requirements were not closely monitored.
Context: The University was not able to meet covenants during the year but obtained a covenant waiver through fiscal year 2024. Additionally, the University did not meet the all the requirements per the USDA loan agreement dated as of December 16, 2021. The following requirements were not met during the fiscal year ended June 30, 2023:
1. Internally produced financial statements within 45 days (Article V, 5.8 (b))
2. Compliance certificate (Article V, 5.8 (c))
3. Budget provided 30 days prior to the beginning of the new fiscal year (Article V, 5.8 (d))
4. Student housing rent roll (Article V, 5.16)
Effect: Lack of compliance with loan covenants and requirements.
Recommendation: The University’s management should read and follow all USDA loan covenants and requirements.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.