2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William
D. Ford Direct Loan Program, ALN #84.268)
Criteria: In accordance with 16 CFR 314.4, a University shall develop, implement, and maintain a
comprehensive information security program that is written in one or more readily accessible parts
and contains administrative, technical, and physical safeguards that are appropriate to your size and
complexity, the nature and scope of your activities, and the sensitivity of any customer information
at issue and must contain all of the elements that are further described in 16 CFR 314.4.
Statement of Condition: During the 2023 audit, it was noted that the University’s Gramm-Leach-
Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In
addition, the application of the comprehensive information security program was not effectively
administered by the University for the 2023 year.
Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in
nature.
Perspective Information: The 2023 audit included testing of the University’s Gramm-Leach-Bliley Act
Policy as outlined in Part 5 of the Compliance Supplement including the application of this program
for the year.
Cause and Effect: Due to lapses of oversight in multiple departments, the University failed to update
their GLBA policy to include the required components in accordance with the Compliance
Supplement. Therefore, the policy is considered incomplete and does not provide the appropriate
disclosures to consumers.
Recommendation: The University should update their Gramm-Leach-Bliley Act Policy to be in
accordance with the requirements and put in place effective controls and practices to ensure the
policy is monitored in a way to ensure it is administered effectively.
View of Responsible Officials: The University has reviewed the Gramm-Leach-Bliley Act Policy and
has put in place controls and practices to ensure the policy is monitored and administered
effectively moving forward.
2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department
of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN
#84.063) (Repeat Finding 2022-002)
Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and
Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the
institution must update the Enrollment Reporting roster file for changes in student status, report the
date the enrollment status was effective, enter the new anticipated completion date, and submit
the changes to NSLDS.
Statement of Condition: During the audit, it was noted that the University incorrectly reported
student enrollment status at changes in enrollment.
Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in
nature.
Perspective Information: The audit included a detailed testing of 40 student files, of which this
significant deficiency applies to 5, indicating an error rate of 12.50%.
Cause and Effect: Due to lapses in communication between departments, in certain instances, the
University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in
misrepresentation within the NSLDS system.
Recommendation: The University should ensure that the correct enrollment status is reported to
NSLDS.
View of Responsible Officials: The University is continuing to improve communication between the
Registrar’s office, Financial Aid office, National Student Clearinghouse, and NSLDS with the goal of
clear and correct reporting to NSLDS. Staff between the different departments have participated in
training on enrollment reporting and how National Student Clearinghouse works directly with
NSLDS. A monthly check list has also been created to make sure items are getting completed.
2023-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $9 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 5, indicating an error rate of 83.30%.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $12 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-006 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(g), for the purpose of calculating the return of unearned
aid upon withdrawal, “institutional charges” are tuition, fees, room and board (if the student
contracts with the institution for the room and board) and other educationally related expenses
assessed by the institution.
Statement of Condition: During the audit, it was noted that the University incorrectly calculated
institutional charges used in determining the amount of unearned aid to withdrawal.
Questioned Costs: The known monetary error is $307 over-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the institutional charges were not calculated
per the stipulations described in the handbook. This could result in a miscalculation of Title IV aid
earned and could result in monetary error.
Recommendation: The University should ensure that the calculation of institutional charges used in
the determination of the return of aid for a payment period in which a student has withdrawn is
formulated correctly utilizing the guidance provided by the Compliance Supplement and the Student
Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department
of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN
#84.063) (Repeat Finding 2022-002)
Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and
Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the
institution must update the Enrollment Reporting roster file for changes in student status, report the
date the enrollment status was effective, enter the new anticipated completion date, and submit
the changes to NSLDS.
Statement of Condition: During the audit, it was noted that the University incorrectly reported
student enrollment status at changes in enrollment.
Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in
nature.
Perspective Information: The audit included a detailed testing of 40 student files, of which this
significant deficiency applies to 5, indicating an error rate of 12.50%.
Cause and Effect: Due to lapses in communication between departments, in certain instances, the
University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in
misrepresentation within the NSLDS system.
Recommendation: The University should ensure that the correct enrollment status is reported to
NSLDS.
View of Responsible Officials: The University is continuing to improve communication between the
Registrar’s office, Financial Aid office, National Student Clearinghouse, and NSLDS with the goal of
clear and correct reporting to NSLDS. Staff between the different departments have participated in
training on enrollment reporting and how National Student Clearinghouse works directly with
NSLDS. A monthly check list has also been created to make sure items are getting completed.
2023-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $9 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 5, indicating an error rate of 83.30%.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $12 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-006 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(g), for the purpose of calculating the return of unearned
aid upon withdrawal, “institutional charges” are tuition, fees, room and board (if the student
contracts with the institution for the room and board) and other educationally related expenses
assessed by the institution.
Statement of Condition: During the audit, it was noted that the University incorrectly calculated
institutional charges used in determining the amount of unearned aid to withdrawal.
Questioned Costs: The known monetary error is $307 over-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the institutional charges were not calculated
per the stipulations described in the handbook. This could result in a miscalculation of Title IV aid
earned and could result in monetary error.
Recommendation: The University should ensure that the calculation of institutional charges used in
the determination of the return of aid for a payment period in which a student has withdrawn is
formulated correctly utilizing the guidance provided by the Compliance Supplement and the Student
Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $9 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 5, indicating an error rate of 83.30%.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $12 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-006 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(g), for the purpose of calculating the return of unearned
aid upon withdrawal, “institutional charges” are tuition, fees, room and board (if the student
contracts with the institution for the room and board) and other educationally related expenses
assessed by the institution.
Statement of Condition: During the audit, it was noted that the University incorrectly calculated
institutional charges used in determining the amount of unearned aid to withdrawal.
Questioned Costs: The known monetary error is $307 over-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the institutional charges were not calculated
per the stipulations described in the handbook. This could result in a miscalculation of Title IV aid
earned and could result in monetary error.
Recommendation: The University should ensure that the calculation of institutional charges used in
the determination of the return of aid for a payment period in which a student has withdrawn is
formulated correctly utilizing the guidance provided by the Compliance Supplement and the Student
Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $9 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 5, indicating an error rate of 83.30%.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $12 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-006 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(g), for the purpose of calculating the return of unearned
aid upon withdrawal, “institutional charges” are tuition, fees, room and board (if the student
contracts with the institution for the room and board) and other educationally related expenses
assessed by the institution.
Statement of Condition: During the audit, it was noted that the University incorrectly calculated
institutional charges used in determining the amount of unearned aid to withdrawal.
Questioned Costs: The known monetary error is $307 over-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the institutional charges were not calculated
per the stipulations described in the handbook. This could result in a miscalculation of Title IV aid
earned and could result in monetary error.
Recommendation: The University should ensure that the calculation of institutional charges used in
the determination of the return of aid for a payment period in which a student has withdrawn is
formulated correctly utilizing the guidance provided by the Compliance Supplement and the Student
Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William
D. Ford Direct Loan Program, ALN #84.268)
Criteria: In accordance with 16 CFR 314.4, a University shall develop, implement, and maintain a
comprehensive information security program that is written in one or more readily accessible parts
and contains administrative, technical, and physical safeguards that are appropriate to your size and
complexity, the nature and scope of your activities, and the sensitivity of any customer information
at issue and must contain all of the elements that are further described in 16 CFR 314.4.
Statement of Condition: During the 2023 audit, it was noted that the University’s Gramm-Leach-
Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In
addition, the application of the comprehensive information security program was not effectively
administered by the University for the 2023 year.
Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in
nature.
Perspective Information: The 2023 audit included testing of the University’s Gramm-Leach-Bliley Act
Policy as outlined in Part 5 of the Compliance Supplement including the application of this program
for the year.
Cause and Effect: Due to lapses of oversight in multiple departments, the University failed to update
their GLBA policy to include the required components in accordance with the Compliance
Supplement. Therefore, the policy is considered incomplete and does not provide the appropriate
disclosures to consumers.
Recommendation: The University should update their Gramm-Leach-Bliley Act Policy to be in
accordance with the requirements and put in place effective controls and practices to ensure the
policy is monitored in a way to ensure it is administered effectively.
View of Responsible Officials: The University has reviewed the Gramm-Leach-Bliley Act Policy and
has put in place controls and practices to ensure the policy is monitored and administered
effectively moving forward.
2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department
of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN
#84.063) (Repeat Finding 2022-002)
Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and
Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the
institution must update the Enrollment Reporting roster file for changes in student status, report the
date the enrollment status was effective, enter the new anticipated completion date, and submit
the changes to NSLDS.
Statement of Condition: During the audit, it was noted that the University incorrectly reported
student enrollment status at changes in enrollment.
Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in
nature.
Perspective Information: The audit included a detailed testing of 40 student files, of which this
significant deficiency applies to 5, indicating an error rate of 12.50%.
Cause and Effect: Due to lapses in communication between departments, in certain instances, the
University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in
misrepresentation within the NSLDS system.
Recommendation: The University should ensure that the correct enrollment status is reported to
NSLDS.
View of Responsible Officials: The University is continuing to improve communication between the
Registrar’s office, Financial Aid office, National Student Clearinghouse, and NSLDS with the goal of
clear and correct reporting to NSLDS. Staff between the different departments have participated in
training on enrollment reporting and how National Student Clearinghouse works directly with
NSLDS. A monthly check list has also been created to make sure items are getting completed.
2023-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $9 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 5, indicating an error rate of 83.30%.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $12 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-006 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(g), for the purpose of calculating the return of unearned
aid upon withdrawal, “institutional charges” are tuition, fees, room and board (if the student
contracts with the institution for the room and board) and other educationally related expenses
assessed by the institution.
Statement of Condition: During the audit, it was noted that the University incorrectly calculated
institutional charges used in determining the amount of unearned aid to withdrawal.
Questioned Costs: The known monetary error is $307 over-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the institutional charges were not calculated
per the stipulations described in the handbook. This could result in a miscalculation of Title IV aid
earned and could result in monetary error.
Recommendation: The University should ensure that the calculation of institutional charges used in
the determination of the return of aid for a payment period in which a student has withdrawn is
formulated correctly utilizing the guidance provided by the Compliance Supplement and the Student
Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department
of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN
#84.063) (Repeat Finding 2022-002)
Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and
Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the
institution must update the Enrollment Reporting roster file for changes in student status, report the
date the enrollment status was effective, enter the new anticipated completion date, and submit
the changes to NSLDS.
Statement of Condition: During the audit, it was noted that the University incorrectly reported
student enrollment status at changes in enrollment.
Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in
nature.
Perspective Information: The audit included a detailed testing of 40 student files, of which this
significant deficiency applies to 5, indicating an error rate of 12.50%.
Cause and Effect: Due to lapses in communication between departments, in certain instances, the
University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in
misrepresentation within the NSLDS system.
Recommendation: The University should ensure that the correct enrollment status is reported to
NSLDS.
View of Responsible Officials: The University is continuing to improve communication between the
Registrar’s office, Financial Aid office, National Student Clearinghouse, and NSLDS with the goal of
clear and correct reporting to NSLDS. Staff between the different departments have participated in
training on enrollment reporting and how National Student Clearinghouse works directly with
NSLDS. A monthly check list has also been created to make sure items are getting completed.
2023-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $9 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 5, indicating an error rate of 83.30%.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $12 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-006 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(g), for the purpose of calculating the return of unearned
aid upon withdrawal, “institutional charges” are tuition, fees, room and board (if the student
contracts with the institution for the room and board) and other educationally related expenses
assessed by the institution.
Statement of Condition: During the audit, it was noted that the University incorrectly calculated
institutional charges used in determining the amount of unearned aid to withdrawal.
Questioned Costs: The known monetary error is $307 over-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the institutional charges were not calculated
per the stipulations described in the handbook. This could result in a miscalculation of Title IV aid
earned and could result in monetary error.
Recommendation: The University should ensure that the calculation of institutional charges used in
the determination of the return of aid for a payment period in which a student has withdrawn is
formulated correctly utilizing the guidance provided by the Compliance Supplement and the Student
Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $9 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 5, indicating an error rate of 83.30%.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $12 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-006 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(g), for the purpose of calculating the return of unearned
aid upon withdrawal, “institutional charges” are tuition, fees, room and board (if the student
contracts with the institution for the room and board) and other educationally related expenses
assessed by the institution.
Statement of Condition: During the audit, it was noted that the University incorrectly calculated
institutional charges used in determining the amount of unearned aid to withdrawal.
Questioned Costs: The known monetary error is $307 over-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the institutional charges were not calculated
per the stipulations described in the handbook. This could result in a miscalculation of Title IV aid
earned and could result in monetary error.
Recommendation: The University should ensure that the calculation of institutional charges used in
the determination of the return of aid for a payment period in which a student has withdrawn is
formulated correctly utilizing the guidance provided by the Compliance Supplement and the Student
Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $9 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 5, indicating an error rate of 83.30%.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $12 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.
2023-006 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(g), for the purpose of calculating the return of unearned
aid upon withdrawal, “institutional charges” are tuition, fees, room and board (if the student
contracts with the institution for the room and board) and other educationally related expenses
assessed by the institution.
Statement of Condition: During the audit, it was noted that the University incorrectly calculated
institutional charges used in determining the amount of unearned aid to withdrawal.
Questioned Costs: The known monetary error is $307 over-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the institutional charges were not calculated
per the stipulations described in the handbook. This could result in a miscalculation of Title IV aid
earned and could result in monetary error.
Recommendation: The University should ensure that the calculation of institutional charges used in
the determination of the return of aid for a payment period in which a student has withdrawn is
formulated correctly utilizing the guidance provided by the Compliance Supplement and the Student
Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.