Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The anticipated disbursement dates in COD were not updated with the actual dates of disbursement when reporting disbursement records for Federal Pell Grants (Pell) and Federal Direct Loans (FDL) to COD. Additionally two students did not have aid posted on their student accounts but it was reported to COD as disbursed.
Criteria: 34CFR 668.164(a)
Questioned Costs: $5,938
Context: 24 of the 55 tested had COD FDL disbursement date errors ranging from 24-25 days for a disbursement batch in March 2023. 1 of the 32 Pell students tested had a COD disbursement date error that was 108 days. 2 of the 55 tested had FDL disbursement amounts reported to COD incorrectly for disbursements not made on the student account. This resulted in incorrectly reporting $3,217 and $2,721 of Federal Direct Loan disbursements for each student, respectively. The University disbursed these amounts on the student accounts at a later date during the audit.
Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students’ accounts. Reconciliations of University records to COD were not completed regularly so the discrepancies between the two systems were not identified and corrected in a timely manner.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates as well as the monitoring of FDL aggregate limits. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The anticipated disbursement dates in COD were not updated with the actual dates of disbursement when reporting disbursement records for Federal Pell Grants (Pell) and Federal Direct Loans (FDL) to COD. Additionally two students did not have aid posted on their student accounts but it was reported to COD as disbursed.
Criteria: 34CFR 668.164(a)
Questioned Costs: $5,938
Context: 24 of the 55 tested had COD FDL disbursement date errors ranging from 24-25 days for a disbursement batch in March 2023. 1 of the 32 Pell students tested had a COD disbursement date error that was 108 days. 2 of the 55 tested had FDL disbursement amounts reported to COD incorrectly for disbursements not made on the student account. This resulted in incorrectly reporting $3,217 and $2,721 of Federal Direct Loan disbursements for each student, respectively. The University disbursed these amounts on the student accounts at a later date during the audit.
Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students’ accounts. Reconciliations of University records to COD were not completed regularly so the discrepancies between the two systems were not identified and corrected in a timely manner.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates as well as the monitoring of FDL aggregate limits. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Unofficial Withdrawals Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not properly evaluate a student as a potential unofficial withdrawal based on all F grades for the Spring 2023 term and did not process a return to Title IV (R2T4) calculation.
Criteria: 34 CFR 668.22
Questioned Costs: $3,460
Context: From our disbursement sample, 1 out of 60 tested did not appear to have been properly evaluated as an unofficial withdrawal based on the student having all F grades for the Spring 2023 term. If the student’s attendance could not be determined for the term, then the University should have processed the return defaulting to 50%. The questioned costs reflect a R2T4 calculation that defaults to 50%.
Cause: Staff turnover and management oversight. The University is to review students with Title IV aid and no passing grades 30 days after the end of each term to determine if the student unofficially stopped attending and unearned Title IV aid should be returned.
Effect: Return of Title IV funds were not performed accurately or timely
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend a zero credit report be run at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Unofficial Withdrawals Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not properly evaluate a student as a potential unofficial withdrawal based on all F grades for the Spring 2023 term and did not process a return to Title IV (R2T4) calculation.
Criteria: 34 CFR 668.22
Questioned Costs: $3,460
Context: From our disbursement sample, 1 out of 60 tested did not appear to have been properly evaluated as an unofficial withdrawal based on the student having all F grades for the Spring 2023 term. If the student’s attendance could not be determined for the term, then the University should have processed the return defaulting to 50%. The questioned costs reflect a R2T4 calculation that defaults to 50%.
Cause: Staff turnover and management oversight. The University is to review students with Title IV aid and no passing grades 30 days after the end of each term to determine if the student unofficially stopped attending and unearned Title IV aid should be returned.
Effect: Return of Title IV funds were not performed accurately or timely
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend a zero credit report be run at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Unofficial Withdrawals Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not properly evaluate a student as a potential unofficial withdrawal based on all F grades for the Spring 2023 term and did not process a return to Title IV (R2T4) calculation.
Criteria: 34 CFR 668.22
Questioned Costs: $3,460
Context: From our disbursement sample, 1 out of 60 tested did not appear to have been properly evaluated as an unofficial withdrawal based on the student having all F grades for the Spring 2023 term. If the student’s attendance could not be determined for the term, then the University should have processed the return defaulting to 50%. The questioned costs reflect a R2T4 calculation that defaults to 50%.
Cause: Staff turnover and management oversight. The University is to review students with Title IV aid and no passing grades 30 days after the end of each term to determine if the student unofficially stopped attending and unearned Title IV aid should be returned.
Effect: Return of Title IV funds were not performed accurately or timely
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend a zero credit report be run at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Direct Loans Reconciliations DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not adequately complete monthly reconciliations for Federal Direct Loans.
Criteria: 34 CFR 685.300(b)(5)
Questioned Costs: $0
Context: During the audit, it was determined that the University did not properly complete the mandatory monthly reconciliations for Federal Direct Loans.
Cause: Staff turnover and management oversight.
Effect: The University was not in compliance with the reconciliation requirements. Errors between disbursements reported to COD and actual disbursements to students’ accounts were not identified and corrected timely.
Identification as repeat finding, if applicable: 2022-004
Recommendation: We recommend that the University review the reconciliation requirements and properly complete the mandatory monthly reconciliations for Federal Direct Loans. The University should also review or refer to the U.S. Department of Education (ED) announcement DL-22-07 which included information to assist higher education institutions with the mandatory reconciliation requirements for the Federal Direct Loan Program.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Title V Grant Cash Management DEPARTMENT OF EDUCATION
ALN #: 84.031S
Federal Award Identification #: P031S200171
Condition: The University did not adequately minimize the time between expenditures and drawdowns.
Criteria: 34 CFR 668.162
Questioned Costs: $0
Context: During our audit, we noted the University had a refundable advance of approximately $269,000 as of July 1, 2022. The University made additional drawdowns totaling approximately $299,000 through September 30, 2022. The University did not have expenditures meeting this total amount of drawdowns until March 2023.
Cause: Management oversight
Effect: Noncompliance with cash management requirements
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend that the University implement and follow a formal process for making drawdowns when or after expenditures have been incurred and require that supporting documentation be retained to support compliance with cash management requirements.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Title V Grant Procurement DEPARTMENT OF EDUCATION
ALN #: 84.031S
Federal Award Identification #: P031S200171
Condition: The University does not have a purchasing or competitive bid policy that follows the federal regulations. The University did not follow its policy and federal procurement requirements when making purchasing and vendor decisions with Title V grant funds.
Criteria: 2 CFR 200.318 through 200.327
Questioned Costs: $0
Context: While the expenditures tested as part of the audit met allowable cost and allowable activities requirements, the University did not follow its competitive bid policy nor were minimum federal procurement requirements followed properly.
Cause: University personnel were unfamiliar with the federal procurement requirements.
Effect: Noncompliance with procurement requirements that could impact future funding opportunities.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University update their policies that follow the federal procurement requirements and the University implement procedures and controls to help prevent deviations from the policies.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently updated its documentation of its information security program, its security risk assessment and safeguards, implemented adequate process for continuous monitoring, implemented sufficient vendor management policies and reviews, updated its incident response plan to cover all components of the revised regulations, nor updated its written annual report to the board to fully align with the regulations.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The anticipated disbursement dates in COD were not updated with the actual dates of disbursement when reporting disbursement records for Federal Pell Grants (Pell) and Federal Direct Loans (FDL) to COD. Additionally two students did not have aid posted on their student accounts but it was reported to COD as disbursed.
Criteria: 34CFR 668.164(a)
Questioned Costs: $5,938
Context: 24 of the 55 tested had COD FDL disbursement date errors ranging from 24-25 days for a disbursement batch in March 2023. 1 of the 32 Pell students tested had a COD disbursement date error that was 108 days. 2 of the 55 tested had FDL disbursement amounts reported to COD incorrectly for disbursements not made on the student account. This resulted in incorrectly reporting $3,217 and $2,721 of Federal Direct Loan disbursements for each student, respectively. The University disbursed these amounts on the student accounts at a later date during the audit.
Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students’ accounts. Reconciliations of University records to COD were not completed regularly so the discrepancies between the two systems were not identified and corrected in a timely manner.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates as well as the monitoring of FDL aggregate limits. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The anticipated disbursement dates in COD were not updated with the actual dates of disbursement when reporting disbursement records for Federal Pell Grants (Pell) and Federal Direct Loans (FDL) to COD. Additionally two students did not have aid posted on their student accounts but it was reported to COD as disbursed.
Criteria: 34CFR 668.164(a)
Questioned Costs: $5,938
Context: 24 of the 55 tested had COD FDL disbursement date errors ranging from 24-25 days for a disbursement batch in March 2023. 1 of the 32 Pell students tested had a COD disbursement date error that was 108 days. 2 of the 55 tested had FDL disbursement amounts reported to COD incorrectly for disbursements not made on the student account. This resulted in incorrectly reporting $3,217 and $2,721 of Federal Direct Loan disbursements for each student, respectively. The University disbursed these amounts on the student accounts at a later date during the audit.
Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students’ accounts. Reconciliations of University records to COD were not completed regularly so the discrepancies between the two systems were not identified and corrected in a timely manner.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates as well as the monitoring of FDL aggregate limits. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Unofficial Withdrawals Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not properly evaluate a student as a potential unofficial withdrawal based on all F grades for the Spring 2023 term and did not process a return to Title IV (R2T4) calculation.
Criteria: 34 CFR 668.22
Questioned Costs: $3,460
Context: From our disbursement sample, 1 out of 60 tested did not appear to have been properly evaluated as an unofficial withdrawal based on the student having all F grades for the Spring 2023 term. If the student’s attendance could not be determined for the term, then the University should have processed the return defaulting to 50%. The questioned costs reflect a R2T4 calculation that defaults to 50%.
Cause: Staff turnover and management oversight. The University is to review students with Title IV aid and no passing grades 30 days after the end of each term to determine if the student unofficially stopped attending and unearned Title IV aid should be returned.
Effect: Return of Title IV funds were not performed accurately or timely
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend a zero credit report be run at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Unofficial Withdrawals Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not properly evaluate a student as a potential unofficial withdrawal based on all F grades for the Spring 2023 term and did not process a return to Title IV (R2T4) calculation.
Criteria: 34 CFR 668.22
Questioned Costs: $3,460
Context: From our disbursement sample, 1 out of 60 tested did not appear to have been properly evaluated as an unofficial withdrawal based on the student having all F grades for the Spring 2023 term. If the student’s attendance could not be determined for the term, then the University should have processed the return defaulting to 50%. The questioned costs reflect a R2T4 calculation that defaults to 50%.
Cause: Staff turnover and management oversight. The University is to review students with Title IV aid and no passing grades 30 days after the end of each term to determine if the student unofficially stopped attending and unearned Title IV aid should be returned.
Effect: Return of Title IV funds were not performed accurately or timely
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend a zero credit report be run at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Unofficial Withdrawals Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not properly evaluate a student as a potential unofficial withdrawal based on all F grades for the Spring 2023 term and did not process a return to Title IV (R2T4) calculation.
Criteria: 34 CFR 668.22
Questioned Costs: $3,460
Context: From our disbursement sample, 1 out of 60 tested did not appear to have been properly evaluated as an unofficial withdrawal based on the student having all F grades for the Spring 2023 term. If the student’s attendance could not be determined for the term, then the University should have processed the return defaulting to 50%. The questioned costs reflect a R2T4 calculation that defaults to 50%.
Cause: Staff turnover and management oversight. The University is to review students with Title IV aid and no passing grades 30 days after the end of each term to determine if the student unofficially stopped attending and unearned Title IV aid should be returned.
Effect: Return of Title IV funds were not performed accurately or timely
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend a zero credit report be run at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Direct Loans Reconciliations DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not adequately complete monthly reconciliations for Federal Direct Loans.
Criteria: 34 CFR 685.300(b)(5)
Questioned Costs: $0
Context: During the audit, it was determined that the University did not properly complete the mandatory monthly reconciliations for Federal Direct Loans.
Cause: Staff turnover and management oversight.
Effect: The University was not in compliance with the reconciliation requirements. Errors between disbursements reported to COD and actual disbursements to students’ accounts were not identified and corrected timely.
Identification as repeat finding, if applicable: 2022-004
Recommendation: We recommend that the University review the reconciliation requirements and properly complete the mandatory monthly reconciliations for Federal Direct Loans. The University should also review or refer to the U.S. Department of Education (ED) announcement DL-22-07 which included information to assist higher education institutions with the mandatory reconciliation requirements for the Federal Direct Loan Program.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Title V Grant Cash Management DEPARTMENT OF EDUCATION
ALN #: 84.031S
Federal Award Identification #: P031S200171
Condition: The University did not adequately minimize the time between expenditures and drawdowns.
Criteria: 34 CFR 668.162
Questioned Costs: $0
Context: During our audit, we noted the University had a refundable advance of approximately $269,000 as of July 1, 2022. The University made additional drawdowns totaling approximately $299,000 through September 30, 2022. The University did not have expenditures meeting this total amount of drawdowns until March 2023.
Cause: Management oversight
Effect: Noncompliance with cash management requirements
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend that the University implement and follow a formal process for making drawdowns when or after expenditures have been incurred and require that supporting documentation be retained to support compliance with cash management requirements.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Title V Grant Procurement DEPARTMENT OF EDUCATION
ALN #: 84.031S
Federal Award Identification #: P031S200171
Condition: The University does not have a purchasing or competitive bid policy that follows the federal regulations. The University did not follow its policy and federal procurement requirements when making purchasing and vendor decisions with Title V grant funds.
Criteria: 2 CFR 200.318 through 200.327
Questioned Costs: $0
Context: While the expenditures tested as part of the audit met allowable cost and allowable activities requirements, the University did not follow its competitive bid policy nor were minimum federal procurement requirements followed properly.
Cause: University personnel were unfamiliar with the federal procurement requirements.
Effect: Noncompliance with procurement requirements that could impact future funding opportunities.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University update their policies that follow the federal procurement requirements and the University implement procedures and controls to help prevent deviations from the policies.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.