FAC Explorer

Audit 300714

FY End
2023-06-30
Total Expended
$32.56M
Findings
42
Programs
4
Organization: Stevenson University, Inc. (MD)
Year: 2023 Accepted: 2024-03-29
Auditor: Bdo USA PC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
389821 2023-001 - - C
389822 2023-001 - - C
389823 2023-002 Significant Deficiency Yes E
389824 2023-002 Significant Deficiency Yes E
389825 2023-002 Significant Deficiency Yes E
389826 2023-002 Significant Deficiency Yes E
389827 2023-003 - - L
389828 2023-003 - - L
389829 2023-004 - Yes L
389830 2023-004 - Yes L
389831 2023-005 Significant Deficiency Yes N
389832 2023-005 Significant Deficiency Yes N
389833 2023-005 Significant Deficiency Yes N
389834 2023-005 Significant Deficiency Yes N
389835 2023-006 - - N
389836 2023-007 - Yes N
389837 2023-008 Significant Deficiency Yes N
389838 2023-008 Significant Deficiency Yes N
389839 2023-008 Significant Deficiency Yes N
389840 2023-009 - - N
389841 2023-009 - - N
966263 2023-001 - - C
966264 2023-001 - - C
966265 2023-002 Significant Deficiency Yes E
966266 2023-002 Significant Deficiency Yes E
966267 2023-002 Significant Deficiency Yes E
966268 2023-002 Significant Deficiency Yes E
966269 2023-003 - - L
966270 2023-003 - - L
966271 2023-004 - Yes L
966272 2023-004 - Yes L
966273 2023-005 Significant Deficiency Yes N
966274 2023-005 Significant Deficiency Yes N
966275 2023-005 Significant Deficiency Yes N
966276 2023-005 Significant Deficiency Yes N
966277 2023-006 - - N
966278 2023-007 - Yes N
966279 2023-008 Significant Deficiency Yes N
966280 2023-008 Significant Deficiency Yes N
966281 2023-008 Significant Deficiency Yes N
966282 2023-009 - - N
966283 2023-009 - - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $27.50M Yes 6
84.063 Federal Pell Grant Program $4.49M Yes 5
84.007 Federal Supplemental Educational Opportunity Grants $301,384 Yes 5
84.033 Federal Work-Study Program $271,413 Yes 5

Contacts

Name Title Type
CVFMED5XEAG7 Mary Elizabeth Schiller-Schwenke Auditee
4433342050 Michael Dannar Auditor
No contacts on file

Notes to SEFA

Title: Basis of Accounting Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) presents the expenditures of federal awards of Stevenson University (the “University”) and is presented on the accrual basis of accounting, which is consistent with the consolidated financial statements. The Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the University. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the University and agencies and departments of the federal government and all subawards made to the University by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. The awards are classified into program categories in accordance with the provisions of Office of Management and Budget (OMB) Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Expenditures for federal student financial aid programs are recognized as incurred and include Federal Pell program grants to students, Federal Direct Loans programs, the federal share of students’ Federal Supplemental Educational Opportunity Grant program grants and Federal Work Study program earnings, and administrative cost allowances, where applicable. Loans made under the Direct Loan programs are disbursed by the federal government. De Minimis Rate Used: N Rate Explanation: As described in Note 4 to the SEFA, the University elected not to use the 10 percent de minimus indirect cost rate allowed under Uniform Guidance. The accompanying schedule of expenditures of federal awards (the “Schedule”) presents the expenditures of federal awards of Stevenson University (the “University”) and is presented on the accrual basis of accounting, which is consistent with the consolidated financial statements. The Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the University. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the University and agencies and departments of the federal government and all subawards made to the University by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. The awards are classified into program categories in accordance with the provisions of Office of Management and Budget (OMB) Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Expenditures for federal student financial aid programs are recognized as incurred and include Federal Pell program grants to students, Federal Direct Loans programs, the federal share of students’ Federal Supplemental Educational Opportunity Grant program grants and Federal Work Study program earnings, and administrative cost allowances, where applicable. Loans made under the Direct Loan programs are disbursed by the federal government.
Title: Summary of Significant Accounting Policies Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) presents the expenditures of federal awards of Stevenson University (the “University”) and is presented on the accrual basis of accounting, which is consistent with the consolidated financial statements. The Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the University. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the University and agencies and departments of the federal government and all subawards made to the University by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. The awards are classified into program categories in accordance with the provisions of Office of Management and Budget (OMB) Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Expenditures for federal student financial aid programs are recognized as incurred and include Federal Pell program grants to students, Federal Direct Loans programs, the federal share of students’ Federal Supplemental Educational Opportunity Grant program grants and Federal Work Study program earnings, and administrative cost allowances, where applicable. Loans made under the Direct Loan programs are disbursed by the federal government. De Minimis Rate Used: N Rate Explanation: As described in Note 4 to the SEFA, the University elected not to use the 10 percent de minimus indirect cost rate allowed under Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting as more fully described in Note 1 to the University’s consolidated financial statements, which is in accordance with the Uniform Guidance. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement.
Title: Federal Student Loan Programs and Related Matters Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) presents the expenditures of federal awards of Stevenson University (the “University”) and is presented on the accrual basis of accounting, which is consistent with the consolidated financial statements. The Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the University. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the University and agencies and departments of the federal government and all subawards made to the University by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. The awards are classified into program categories in accordance with the provisions of Office of Management and Budget (OMB) Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Expenditures for federal student financial aid programs are recognized as incurred and include Federal Pell program grants to students, Federal Direct Loans programs, the federal share of students’ Federal Supplemental Educational Opportunity Grant program grants and Federal Work Study program earnings, and administrative cost allowances, where applicable. Loans made under the Direct Loan programs are disbursed by the federal government. De Minimis Rate Used: N Rate Explanation: As described in Note 4 to the SEFA, the University elected not to use the 10 percent de minimus indirect cost rate allowed under Uniform Guidance. The University is responsible only for the performance of certain administrative duties with respect to the Federal Direct Loan Program (ALN: 84.268), and accordingly these loans are not included in its consolidated financial statements and it is not practical to determine the balance of loans outstanding to students and former students of the University under these programs as of June 30, 2023. The principal amount of loans disbursed was $27,502,808 for the year ended June 30, 2023.
Title: Indirect Cost Rate Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) presents the expenditures of federal awards of Stevenson University (the “University”) and is presented on the accrual basis of accounting, which is consistent with the consolidated financial statements. The Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the University. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the University and agencies and departments of the federal government and all subawards made to the University by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. The awards are classified into program categories in accordance with the provisions of Office of Management and Budget (OMB) Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Expenditures for federal student financial aid programs are recognized as incurred and include Federal Pell program grants to students, Federal Direct Loans programs, the federal share of students’ Federal Supplemental Educational Opportunity Grant program grants and Federal Work Study program earnings, and administrative cost allowances, where applicable. Loans made under the Direct Loan programs are disbursed by the federal government. De Minimis Rate Used: N Rate Explanation: As described in Note 4 to the SEFA, the University elected not to use the 10 percent de minimus indirect cost rate allowed under Uniform Guidance. The University has elected not to use the 10 percent de minimus indirect cost rate allowed under Uniform Guidance.
Title: Contingency Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) presents the expenditures of federal awards of Stevenson University (the “University”) and is presented on the accrual basis of accounting, which is consistent with the consolidated financial statements. The Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the University. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the University and agencies and departments of the federal government and all subawards made to the University by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. The awards are classified into program categories in accordance with the provisions of Office of Management and Budget (OMB) Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Expenditures for federal student financial aid programs are recognized as incurred and include Federal Pell program grants to students, Federal Direct Loans programs, the federal share of students’ Federal Supplemental Educational Opportunity Grant program grants and Federal Work Study program earnings, and administrative cost allowances, where applicable. Loans made under the Direct Loan programs are disbursed by the federal government. De Minimis Rate Used: N Rate Explanation: As described in Note 4 to the SEFA, the University elected not to use the 10 percent de minimus indirect cost rate allowed under Uniform Guidance. The grant revenue amounts received are subject to audit and adjustment. If any expenditures are disallowed by the grantor agencies as a result of such an audit, any claim for reimbursement to the grantor agencies would become a liability of the University. In the opinion of management, and with the exception of certain findings presented in the accompanying schedule of findings and questioned costs, all grant expenditures are in compliance with the terms of the grant agreements and applicable federal and state laws and regulations.

Finding Details

Finding 2023-001
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance is allowed and considered tolerable if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: Various instances were identified during the year in which funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The University was not in compliance with Cash Management compliance requirements. Questioned Costs: None. Context: During our testing, we identified 2 instances of cash held in excess of allowable time frames for the Federal Supplemental Educational Opportunity Grant (“FSEOG”) Program. Additionally, we identified 2 instances of cash held in excess of allowable time frames for the Federal Work Study (“FWS”) Program. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures over the cash management process to ensure that excess cash is returned timely, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The FWS Program instances were the result of a minor type error on the federal draw reconciliation worksheet. To prevent a similar error in the future, the Business Office has modified its draw recordkeeping process to require the employees that record or approve the draw journal entry also review the draw worksheet for accuracy and correct if needed. The FSEOG Program instances resulted from reversals of student awards in fiscal year 2024 for the fiscal year 2023. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded in a prior fiscal year can be offset by current year activity and missed. The Financial Aid Office will be responsible to notify the Business Office when they initiate prior award transactions. In addition to the weekly monitoring of the related general ledger accounts, the Business Office will also generate financial aid award reporting and monitor for changes.
Finding 2023-001
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance is allowed and considered tolerable if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: Various instances were identified during the year in which funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The University was not in compliance with Cash Management compliance requirements. Questioned Costs: None. Context: During our testing, we identified 2 instances of cash held in excess of allowable time frames for the Federal Supplemental Educational Opportunity Grant (“FSEOG”) Program. Additionally, we identified 2 instances of cash held in excess of allowable time frames for the Federal Work Study (“FWS”) Program. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures over the cash management process to ensure that excess cash is returned timely, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The FWS Program instances were the result of a minor type error on the federal draw reconciliation worksheet. To prevent a similar error in the future, the Business Office has modified its draw recordkeeping process to require the employees that record or approve the draw journal entry also review the draw worksheet for accuracy and correct if needed. The FSEOG Program instances resulted from reversals of student awards in fiscal year 2024 for the fiscal year 2023. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded in a prior fiscal year can be offset by current year activity and missed. The Financial Aid Office will be responsible to notify the Business Office when they initiate prior award transactions. In addition to the weekly monitoring of the related general ledger accounts, the Business Office will also generate financial aid award reporting and monitor for changes.
Finding 2023-002
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Calculation of Benefits – Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility – Federal Pell Grant (Assistance Listing 84.063) – Each year, based on the maximum Pell Grant established by Congress, the ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (“EFC”) and COA. The Disbursement Schedules are used to determine annual awards for full time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student’s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. E. Eligibility – Federal Supplemental Educational Opportunity Grant (Assistance Listing 84.007) - The FSEOG program provides grants to eligible undergraduate students who have not previously earned a bachelor’s or first professional degree. Priority is given to Pell Grant recipients who have the lowest expected family contributions. The institution decides the amount of the grant, which can be up to $4,000 but not less than $100, for an academic year (34 CFR 676.10 and 676.20). Condition: For certain students identified through our testing, the University did not properly calculate the student’s COA. Additionally, for certain students, the University improperly calculated the student’s Pell award. Furthermore, for certain students, the University awarded and disbursed FSEOG funds in excess of the annual maximum. Finally, the University did not give priority to Federal Pell Grant recipients when awarding and disbursing FSEOG funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students’ COAs, calculate eligible award amounts, and properly award aid in-line with the required guidelines could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: For 4 of 25 students selected for testing, the University did not properly calculate the student’s COA. For 1 of 25 students selected for testing, the University did not properly calculate the student’s Pell award. For 1 of 25 students selected for testing, the University disbursed FSEOG funds in excess of the annual maximum grant allowed. 11 students disbursed FSEOG funds during the year were improperly given priority over Federal Pell Grant recipients. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures, and internal controls to ensure that Title IV aid is properly calculated, awarded, and disbursed, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly. For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs.
Finding 2023-002
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Calculation of Benefits – Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility – Federal Pell Grant (Assistance Listing 84.063) – Each year, based on the maximum Pell Grant established by Congress, the ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (“EFC”) and COA. The Disbursement Schedules are used to determine annual awards for full time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student’s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. E. Eligibility – Federal Supplemental Educational Opportunity Grant (Assistance Listing 84.007) - The FSEOG program provides grants to eligible undergraduate students who have not previously earned a bachelor’s or first professional degree. Priority is given to Pell Grant recipients who have the lowest expected family contributions. The institution decides the amount of the grant, which can be up to $4,000 but not less than $100, for an academic year (34 CFR 676.10 and 676.20). Condition: For certain students identified through our testing, the University did not properly calculate the student’s COA. Additionally, for certain students, the University improperly calculated the student’s Pell award. Furthermore, for certain students, the University awarded and disbursed FSEOG funds in excess of the annual maximum. Finally, the University did not give priority to Federal Pell Grant recipients when awarding and disbursing FSEOG funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students’ COAs, calculate eligible award amounts, and properly award aid in-line with the required guidelines could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: For 4 of 25 students selected for testing, the University did not properly calculate the student’s COA. For 1 of 25 students selected for testing, the University did not properly calculate the student’s Pell award. For 1 of 25 students selected for testing, the University disbursed FSEOG funds in excess of the annual maximum grant allowed. 11 students disbursed FSEOG funds during the year were improperly given priority over Federal Pell Grant recipients. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures, and internal controls to ensure that Title IV aid is properly calculated, awarded, and disbursed, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly. For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs.
Finding 2023-002
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Calculation of Benefits – Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility – Federal Pell Grant (Assistance Listing 84.063) – Each year, based on the maximum Pell Grant established by Congress, the ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (“EFC”) and COA. The Disbursement Schedules are used to determine annual awards for full time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student’s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. E. Eligibility – Federal Supplemental Educational Opportunity Grant (Assistance Listing 84.007) - The FSEOG program provides grants to eligible undergraduate students who have not previously earned a bachelor’s or first professional degree. Priority is given to Pell Grant recipients who have the lowest expected family contributions. The institution decides the amount of the grant, which can be up to $4,000 but not less than $100, for an academic year (34 CFR 676.10 and 676.20). Condition: For certain students identified through our testing, the University did not properly calculate the student’s COA. Additionally, for certain students, the University improperly calculated the student’s Pell award. Furthermore, for certain students, the University awarded and disbursed FSEOG funds in excess of the annual maximum. Finally, the University did not give priority to Federal Pell Grant recipients when awarding and disbursing FSEOG funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students’ COAs, calculate eligible award amounts, and properly award aid in-line with the required guidelines could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: For 4 of 25 students selected for testing, the University did not properly calculate the student’s COA. For 1 of 25 students selected for testing, the University did not properly calculate the student’s Pell award. For 1 of 25 students selected for testing, the University disbursed FSEOG funds in excess of the annual maximum grant allowed. 11 students disbursed FSEOG funds during the year were improperly given priority over Federal Pell Grant recipients. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures, and internal controls to ensure that Title IV aid is properly calculated, awarded, and disbursed, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly. For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs.
Finding 2023-002
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Calculation of Benefits – Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility – Federal Pell Grant (Assistance Listing 84.063) – Each year, based on the maximum Pell Grant established by Congress, the ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (“EFC”) and COA. The Disbursement Schedules are used to determine annual awards for full time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student’s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. E. Eligibility – Federal Supplemental Educational Opportunity Grant (Assistance Listing 84.007) - The FSEOG program provides grants to eligible undergraduate students who have not previously earned a bachelor’s or first professional degree. Priority is given to Pell Grant recipients who have the lowest expected family contributions. The institution decides the amount of the grant, which can be up to $4,000 but not less than $100, for an academic year (34 CFR 676.10 and 676.20). Condition: For certain students identified through our testing, the University did not properly calculate the student’s COA. Additionally, for certain students, the University improperly calculated the student’s Pell award. Furthermore, for certain students, the University awarded and disbursed FSEOG funds in excess of the annual maximum. Finally, the University did not give priority to Federal Pell Grant recipients when awarding and disbursing FSEOG funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students’ COAs, calculate eligible award amounts, and properly award aid in-line with the required guidelines could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: For 4 of 25 students selected for testing, the University did not properly calculate the student’s COA. For 1 of 25 students selected for testing, the University did not properly calculate the student’s Pell award. For 1 of 25 students selected for testing, the University disbursed FSEOG funds in excess of the annual maximum grant allowed. 11 students disbursed FSEOG funds during the year were improperly given priority over Federal Pell Grant recipients. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures, and internal controls to ensure that Title IV aid is properly calculated, awarded, and disbursed, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly. For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs.
Finding 2023-003
Federal Program Information: Federal Pell Grant Program (ALN: 84.063) and Federal Direct Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Financial Reporting – Federal regulations require the University to submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, COA, and the “Academic Start Date” and “Academic End Date”. Institutions must also submit disbursement records to the COD for students no earlier than 7 calendar days prior to the disbursement date, and no later than 15 calendar days after the institution makes a disbursement. Condition: For certain students identified through our testing, errors were identified in key items reported to the COD in student origination records. Additionally, the University failed to report disbursement records for certain students within the required timeframe. Cause: Administrative oversight with respect to accurate reporting of federal award information. Effect or Potential Effect: The University was not in compliance with COD reporting requirements. Questioned Costs: None. Context: We noted the following exceptions: For 5 of 25 students selected for origination record testing, the student’s COA was inaccurately reported within the COD system. For 1 of 25 students selected for origination record testing, the “Academic Start Date” was inaccurately reported. For 2 of 25 students selected for disbursement record testing, the University waited more than 15 days after making a disbursement of funds to report the required disbursement information. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its procedures to ensure origination and disbursement records are reported accurately and timely to the COD for Federal Direct Loan Program and Federal Pell Grant Program recipients, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual to an automated review process. The COA data that was inputted at the beginning of the award year did not match all budget components causing inaccuracies. The Financial Aid office was adjusting the budget components of the COA manually, which resulted in miscalculations. When these calculations were performed COD might not have been updated and therefore the COA could be inaccurately reported. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes. The Financial Aid office will review all student COA calculations to ensure that the COA used for originating and disbursing funds is correct. The Financial Aid office will set up automatic processing of key reports to identify rejected origination records. The Financial Aid office will set up the Direct Loan COD Reject Report (DCRR) and the Pell COD Reject Report (PCRR) to run Sunday night and be available Monday morning to be reviewed by the Financial Aid Advisors. The Financial Aid office will make the necessary corrections and update by the end of the week. The Financial Aid office will run Batch FA Transmittal Register (FATR) to confirm that all anticipated awards have passed all rules and are ready to transmit. Those that don’t pass will be reviewed and students will be contacted for updated/corrected information. COD records will be exported nightly through an automated process to ensure all deadlines are met and that we are not exceeding the 15 calendar day limit. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which will eliminate the need for any manual calculations of COA. This automated process should eliminate improperly calculated COAs.
Finding 2023-003
Federal Program Information: Federal Pell Grant Program (ALN: 84.063) and Federal Direct Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Financial Reporting – Federal regulations require the University to submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, COA, and the “Academic Start Date” and “Academic End Date”. Institutions must also submit disbursement records to the COD for students no earlier than 7 calendar days prior to the disbursement date, and no later than 15 calendar days after the institution makes a disbursement. Condition: For certain students identified through our testing, errors were identified in key items reported to the COD in student origination records. Additionally, the University failed to report disbursement records for certain students within the required timeframe. Cause: Administrative oversight with respect to accurate reporting of federal award information. Effect or Potential Effect: The University was not in compliance with COD reporting requirements. Questioned Costs: None. Context: We noted the following exceptions: For 5 of 25 students selected for origination record testing, the student’s COA was inaccurately reported within the COD system. For 1 of 25 students selected for origination record testing, the “Academic Start Date” was inaccurately reported. For 2 of 25 students selected for disbursement record testing, the University waited more than 15 days after making a disbursement of funds to report the required disbursement information. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its procedures to ensure origination and disbursement records are reported accurately and timely to the COD for Federal Direct Loan Program and Federal Pell Grant Program recipients, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual to an automated review process. The COA data that was inputted at the beginning of the award year did not match all budget components causing inaccuracies. The Financial Aid office was adjusting the budget components of the COA manually, which resulted in miscalculations. When these calculations were performed COD might not have been updated and therefore the COA could be inaccurately reported. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes. The Financial Aid office will review all student COA calculations to ensure that the COA used for originating and disbursing funds is correct. The Financial Aid office will set up automatic processing of key reports to identify rejected origination records. The Financial Aid office will set up the Direct Loan COD Reject Report (DCRR) and the Pell COD Reject Report (PCRR) to run Sunday night and be available Monday morning to be reviewed by the Financial Aid Advisors. The Financial Aid office will make the necessary corrections and update by the end of the week. The Financial Aid office will run Batch FA Transmittal Register (FATR) to confirm that all anticipated awards have passed all rules and are ready to transmit. Those that don’t pass will be reviewed and students will be contacted for updated/corrected information. COD records will be exported nightly through an automated process to ensure all deadlines are met and that we are not exceeding the 15 calendar day limit. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which will eliminate the need for any manual calculations of COA. This automated process should eliminate improperly calculated COAs.
Finding 2023-004
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Special Reporting – The Fiscal Operations Report and Application to Participate (“FISAP”) is an electronic report submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Key line items containing critical information include: Part I, Identifying Information, Certification, and Warning; Part II, Application to Participate (selected sections); Part III, Fiscal Operations Report, Part IV, Fiscal Operations Report Federal Supplemental Educational Opportunity Grant Program; Part V, Fiscal Operations Report Federal Work-Study Program; and Part VI, Program Summary for Award Year. The FISAP must be submitted each year by the deadline established by the ED. Condition: The University was unable to provide supporting documentation for certain key line items of the submitted FISAP. Cause: Administrative oversight with respect to FISAP reporting. Effect or Potential Effect: The University is not in compliance with FISAP reporting requirements. Failure to report accurate records of expenditures for the previous award year could impact future availability of Title IV aid. Questioned Costs: None. Context: The University was unable to reproduce the reports used to prepare Part VI, Section A of the FISAP. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-002 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies and procedures to ensure that reports used to prepare the annual FISAP are retained, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: After running the FISAP required reports in Colleague, the Financial Aid office will be required to save the reports so they are available to be used as supporting documents. This past year after the data was collected and the reports ran in Colleague the reports were not saved to the network drive and were lost. The reports cannot be recreated at a later date.
Finding 2023-004
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Special Reporting – The Fiscal Operations Report and Application to Participate (“FISAP”) is an electronic report submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Key line items containing critical information include: Part I, Identifying Information, Certification, and Warning; Part II, Application to Participate (selected sections); Part III, Fiscal Operations Report, Part IV, Fiscal Operations Report Federal Supplemental Educational Opportunity Grant Program; Part V, Fiscal Operations Report Federal Work-Study Program; and Part VI, Program Summary for Award Year. The FISAP must be submitted each year by the deadline established by the ED. Condition: The University was unable to provide supporting documentation for certain key line items of the submitted FISAP. Cause: Administrative oversight with respect to FISAP reporting. Effect or Potential Effect: The University is not in compliance with FISAP reporting requirements. Failure to report accurate records of expenditures for the previous award year could impact future availability of Title IV aid. Questioned Costs: None. Context: The University was unable to reproduce the reports used to prepare Part VI, Section A of the FISAP. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-002 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies and procedures to ensure that reports used to prepare the annual FISAP are retained, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: After running the FISAP required reports in Colleague, the Financial Aid office will be required to save the reports so they are available to be used as supporting documents. This past year after the data was collected and the reports ran in Colleague the reports were not saved to the network drive and were lost. The reports cannot be recreated at a later date.
Finding 2023-005
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. Cause: Administrative oversight and lack of sufficient internal controls with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Sampled questioned costs: $3,645; total questioned costs: indeterminable. Context: For 4 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations. Views of Responsible Officials and Planned Corrective Actions: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors in verifying certain data when performing verification. The previous Financial Aid Director was terminated before the prior corrective action plan could be completed. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will implement a Quality Assurance two-step verification process. The financial aid advisor will work with the student to gather necessary documents and perform the original verification. The Associate Director of Financial Aid will review these verifications and update them in Colleague to be transmitted to COD for corrections if needed. The Financial Aid office will run a report to identify all students selected for verification for 2023-2024 and review them for accuracy. If any corrections are needed they will be updated and awards will be adjusted as needed.
Finding 2023-005
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. Cause: Administrative oversight and lack of sufficient internal controls with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Sampled questioned costs: $3,645; total questioned costs: indeterminable. Context: For 4 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations. Views of Responsible Officials and Planned Corrective Actions: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors in verifying certain data when performing verification. The previous Financial Aid Director was terminated before the prior corrective action plan could be completed. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will implement a Quality Assurance two-step verification process. The financial aid advisor will work with the student to gather necessary documents and perform the original verification. The Associate Director of Financial Aid will review these verifications and update them in Colleague to be transmitted to COD for corrections if needed. The Financial Aid office will run a report to identify all students selected for verification for 2023-2024 and review them for accuracy. If any corrections are needed they will be updated and awards will be adjusted as needed.
Finding 2023-005
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. Cause: Administrative oversight and lack of sufficient internal controls with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Sampled questioned costs: $3,645; total questioned costs: indeterminable. Context: For 4 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations. Views of Responsible Officials and Planned Corrective Actions: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors in verifying certain data when performing verification. The previous Financial Aid Director was terminated before the prior corrective action plan could be completed. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will implement a Quality Assurance two-step verification process. The financial aid advisor will work with the student to gather necessary documents and perform the original verification. The Associate Director of Financial Aid will review these verifications and update them in Colleague to be transmitted to COD for corrections if needed. The Financial Aid office will run a report to identify all students selected for verification for 2023-2024 and review them for accuracy. If any corrections are needed they will be updated and awards will be adjusted as needed.
Finding 2023-005
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. Cause: Administrative oversight and lack of sufficient internal controls with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Sampled questioned costs: $3,645; total questioned costs: indeterminable. Context: For 4 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations. Views of Responsible Officials and Planned Corrective Actions: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors in verifying certain data when performing verification. The previous Financial Aid Director was terminated before the prior corrective action plan could be completed. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will implement a Quality Assurance two-step verification process. The financial aid advisor will work with the student to gather necessary documents and perform the original verification. The Associate Director of Financial Aid will review these verifications and update them in Colleague to be transmitted to COD for corrections if needed. The Financial Aid office will run a report to identify all students selected for verification for 2023-2024 and review them for accuracy. If any corrections are needed they will be updated and awards will be adjusted as needed.
Finding 2023-006
Federal Program Information: Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements To or On Behalf of Students – Federal Work Study – Before an institution makes an initial disbursement of FWS compensation to a student for an award period, the institution must notify the student of the amount of funds the student is authorized to earn, and how and when the FWS compensation will be paid (34 CFR 675.16(a)(3)). The institution must also establish and maintain program and fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day (34 CFR 675.19(b)(2)(i)). Condition: For certain students selected for testing, the University was unable to support that students were notified of the terms of their award prior to disbursing FWS compensation. Cause: Administrative oversight with respect to FWS compensation. Effect: Students were not properly notified of the terms and conditions of their FWS compensation in accordance with federal regulations. Questioned Costs: None. Context: For 4 of 13 students selected for testing, the University was unable to provide documentation supporting that students were properly notified of the terms and conditions of their FWS compensation. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures over FWS compensation to ensure that students are properly notified of the terms of their compensation. Views of Responsible Officials and Planned Corrective Actions: In an effort to maximize the utilization of student aid, current student workers were reviewed for FWS eligibility. Those students identified were awarded the FWS funds without being notified though they did indicate they were interested in FWS funds. The Financial Aid Office and Human Resources will collaborate to ensure that work study students are not allowed to start work until they have followed proper hiring procedures within the PeopleAdmin system. The Financial Aid office is also modifying the way this award will be offered in 2024-2025. The Financial Aid office will add this award to the automated process when students are first packaged. At that time, they will need to accept or decline the offer. From acceptance, the student will be prompted to complete a short training video on acquiring a University job. Upon completion of the video the students will be provided an automated link to the PeopleAdmin system where they will have access to the open jobs on campus. The Financial Aid office will receive an automated confirmation from the PeopleAdmin system that all necessary documents and training have been completed. The Financial Aid office will assign an individual to oversee this process.
Finding 2023-007
Federal Program Information: Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account. Condition: Certain borrowers did not receive a loan disbursement notification, or the University was unable to provide a copy of the loan disbursement notification sent to the student. Cause: Administrative oversight with respect to loan disbursement notifications. Effect: Students and/or parents were not properly notified of loan disbursements and/or their right to cancel/decline loan awards. Questioned Costs: None. Context: For 2 of 40 students selected for testing, the University was unable to provide documentation supporting appropriate loan disbursement notification. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-004 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures over loan disbursement notifications to ensure that such notifications are sent to student and/or parent borrowers within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: The Financial Aid office made several staffing changes in 2022-2023. The loan coordinator left the institution. Newly hired staff were not properly trained, resulting in the failure to carry out loan notification as required. The VP of Enrollment created a process, implemented in the Spring of 2023, that automated the student loan disbursement notifications with-in the required 30 days of student accounts transmitting their loans.
Finding 2023-008
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard termbased institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amounts to be returned to the ED. Additionally, the University was unable to provide evidence of approval from the borrower prior to making a post-withdrawal disbursement of loan funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to return of Title IV fund calculations and post-withdrawal disbursements. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Sampled questioned costs: $12,572; total questioned costs: indeterminable. Context: For 3 of 5 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. Additionally, funds due for return were either not returned or were not returned timely for 3 of 5 students. For 1 of 5 students selected for testing, the University did not retain documentation of the student’s or parent’s approval obtained prior to making a post-withdrawal disbursement of loan funds. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-005 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, and that adequate records are maintained to support proper procedures for post-withdrawal disbursements. Views of Responsible Officials and Planned Corrective Actions: The Financial Aid office made several staffing changes in 2022-2023. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, has developed an automated weekly report confirming student withdrawal dates. The report is scheduled to be emailed to Financial Aid office every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of title IV funds calculation would be performed for those students. Any funds required to be disbursed or returned would then be processed.
Finding 2023-008
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard termbased institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amounts to be returned to the ED. Additionally, the University was unable to provide evidence of approval from the borrower prior to making a post-withdrawal disbursement of loan funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to return of Title IV fund calculations and post-withdrawal disbursements. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Sampled questioned costs: $12,572; total questioned costs: indeterminable. Context: For 3 of 5 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. Additionally, funds due for return were either not returned or were not returned timely for 3 of 5 students. For 1 of 5 students selected for testing, the University did not retain documentation of the student’s or parent’s approval obtained prior to making a post-withdrawal disbursement of loan funds. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-005 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, and that adequate records are maintained to support proper procedures for post-withdrawal disbursements. Views of Responsible Officials and Planned Corrective Actions: The Financial Aid office made several staffing changes in 2022-2023. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, has developed an automated weekly report confirming student withdrawal dates. The report is scheduled to be emailed to Financial Aid office every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of title IV funds calculation would be performed for those students. Any funds required to be disbursed or returned would then be processed.
Finding 2023-008
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard termbased institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amounts to be returned to the ED. Additionally, the University was unable to provide evidence of approval from the borrower prior to making a post-withdrawal disbursement of loan funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to return of Title IV fund calculations and post-withdrawal disbursements. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Sampled questioned costs: $12,572; total questioned costs: indeterminable. Context: For 3 of 5 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. Additionally, funds due for return were either not returned or were not returned timely for 3 of 5 students. For 1 of 5 students selected for testing, the University did not retain documentation of the student’s or parent’s approval obtained prior to making a post-withdrawal disbursement of loan funds. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-005 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, and that adequate records are maintained to support proper procedures for post-withdrawal disbursements. Views of Responsible Officials and Planned Corrective Actions: The Financial Aid office made several staffing changes in 2022-2023. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, has developed an automated weekly report confirming student withdrawal dates. The report is scheduled to be emailed to Financial Aid office every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of title IV funds calculation would be performed for those students. Any funds required to be disbursed or returned would then be processed.
Finding 2023-009
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: The University did not accurately report certain significant data elements to the NSLDS website for certain students who graduated, withdrew, or had an increase/decrease in attendance level during the year. Additionally, the University’s fiscal year SCHER1 report included multiple instances in which error records were not corrected within the required timeframe. Cause: Administrative oversight with respect to enrollment reporting compliance requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions as a result of our procedures: For 3 of 25 students sampled whose status changed during the year, the University failed to accurately report all significant data elements under the Program-Level Record in a timely notification to the NSLDS website. For 4 of 5 Error Reports tested, error records identified in the Error/Acknowledgment files were not corrected within the required timeframe. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University Registrar will develop a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions in the Registrar's Office. Enrollment reporting is a critical function that will be prioritized in the implementation of the referenced plan.
Finding 2023-009
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: The University did not accurately report certain significant data elements to the NSLDS website for certain students who graduated, withdrew, or had an increase/decrease in attendance level during the year. Additionally, the University’s fiscal year SCHER1 report included multiple instances in which error records were not corrected within the required timeframe. Cause: Administrative oversight with respect to enrollment reporting compliance requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions as a result of our procedures: For 3 of 25 students sampled whose status changed during the year, the University failed to accurately report all significant data elements under the Program-Level Record in a timely notification to the NSLDS website. For 4 of 5 Error Reports tested, error records identified in the Error/Acknowledgment files were not corrected within the required timeframe. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University Registrar will develop a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions in the Registrar's Office. Enrollment reporting is a critical function that will be prioritized in the implementation of the referenced plan.
Finding 2023-001
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance is allowed and considered tolerable if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: Various instances were identified during the year in which funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The University was not in compliance with Cash Management compliance requirements. Questioned Costs: None. Context: During our testing, we identified 2 instances of cash held in excess of allowable time frames for the Federal Supplemental Educational Opportunity Grant (“FSEOG”) Program. Additionally, we identified 2 instances of cash held in excess of allowable time frames for the Federal Work Study (“FWS”) Program. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures over the cash management process to ensure that excess cash is returned timely, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The FWS Program instances were the result of a minor type error on the federal draw reconciliation worksheet. To prevent a similar error in the future, the Business Office has modified its draw recordkeeping process to require the employees that record or approve the draw journal entry also review the draw worksheet for accuracy and correct if needed. The FSEOG Program instances resulted from reversals of student awards in fiscal year 2024 for the fiscal year 2023. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded in a prior fiscal year can be offset by current year activity and missed. The Financial Aid Office will be responsible to notify the Business Office when they initiate prior award transactions. In addition to the weekly monitoring of the related general ledger accounts, the Business Office will also generate financial aid award reporting and monitor for changes.
Finding 2023-001
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance is allowed and considered tolerable if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: Various instances were identified during the year in which funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The University was not in compliance with Cash Management compliance requirements. Questioned Costs: None. Context: During our testing, we identified 2 instances of cash held in excess of allowable time frames for the Federal Supplemental Educational Opportunity Grant (“FSEOG”) Program. Additionally, we identified 2 instances of cash held in excess of allowable time frames for the Federal Work Study (“FWS”) Program. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures over the cash management process to ensure that excess cash is returned timely, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The FWS Program instances were the result of a minor type error on the federal draw reconciliation worksheet. To prevent a similar error in the future, the Business Office has modified its draw recordkeeping process to require the employees that record or approve the draw journal entry also review the draw worksheet for accuracy and correct if needed. The FSEOG Program instances resulted from reversals of student awards in fiscal year 2024 for the fiscal year 2023. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded in a prior fiscal year can be offset by current year activity and missed. The Financial Aid Office will be responsible to notify the Business Office when they initiate prior award transactions. In addition to the weekly monitoring of the related general ledger accounts, the Business Office will also generate financial aid award reporting and monitor for changes.
Finding 2023-002
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Calculation of Benefits – Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility – Federal Pell Grant (Assistance Listing 84.063) – Each year, based on the maximum Pell Grant established by Congress, the ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (“EFC”) and COA. The Disbursement Schedules are used to determine annual awards for full time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student’s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. E. Eligibility – Federal Supplemental Educational Opportunity Grant (Assistance Listing 84.007) - The FSEOG program provides grants to eligible undergraduate students who have not previously earned a bachelor’s or first professional degree. Priority is given to Pell Grant recipients who have the lowest expected family contributions. The institution decides the amount of the grant, which can be up to $4,000 but not less than $100, for an academic year (34 CFR 676.10 and 676.20). Condition: For certain students identified through our testing, the University did not properly calculate the student’s COA. Additionally, for certain students, the University improperly calculated the student’s Pell award. Furthermore, for certain students, the University awarded and disbursed FSEOG funds in excess of the annual maximum. Finally, the University did not give priority to Federal Pell Grant recipients when awarding and disbursing FSEOG funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students’ COAs, calculate eligible award amounts, and properly award aid in-line with the required guidelines could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: For 4 of 25 students selected for testing, the University did not properly calculate the student’s COA. For 1 of 25 students selected for testing, the University did not properly calculate the student’s Pell award. For 1 of 25 students selected for testing, the University disbursed FSEOG funds in excess of the annual maximum grant allowed. 11 students disbursed FSEOG funds during the year were improperly given priority over Federal Pell Grant recipients. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures, and internal controls to ensure that Title IV aid is properly calculated, awarded, and disbursed, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly. For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs.
Finding 2023-002
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Calculation of Benefits – Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility – Federal Pell Grant (Assistance Listing 84.063) – Each year, based on the maximum Pell Grant established by Congress, the ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (“EFC”) and COA. The Disbursement Schedules are used to determine annual awards for full time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student’s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. E. Eligibility – Federal Supplemental Educational Opportunity Grant (Assistance Listing 84.007) - The FSEOG program provides grants to eligible undergraduate students who have not previously earned a bachelor’s or first professional degree. Priority is given to Pell Grant recipients who have the lowest expected family contributions. The institution decides the amount of the grant, which can be up to $4,000 but not less than $100, for an academic year (34 CFR 676.10 and 676.20). Condition: For certain students identified through our testing, the University did not properly calculate the student’s COA. Additionally, for certain students, the University improperly calculated the student’s Pell award. Furthermore, for certain students, the University awarded and disbursed FSEOG funds in excess of the annual maximum. Finally, the University did not give priority to Federal Pell Grant recipients when awarding and disbursing FSEOG funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students’ COAs, calculate eligible award amounts, and properly award aid in-line with the required guidelines could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: For 4 of 25 students selected for testing, the University did not properly calculate the student’s COA. For 1 of 25 students selected for testing, the University did not properly calculate the student’s Pell award. For 1 of 25 students selected for testing, the University disbursed FSEOG funds in excess of the annual maximum grant allowed. 11 students disbursed FSEOG funds during the year were improperly given priority over Federal Pell Grant recipients. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures, and internal controls to ensure that Title IV aid is properly calculated, awarded, and disbursed, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly. For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs.
Finding 2023-002
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Calculation of Benefits – Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility – Federal Pell Grant (Assistance Listing 84.063) – Each year, based on the maximum Pell Grant established by Congress, the ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (“EFC”) and COA. The Disbursement Schedules are used to determine annual awards for full time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student’s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. E. Eligibility – Federal Supplemental Educational Opportunity Grant (Assistance Listing 84.007) - The FSEOG program provides grants to eligible undergraduate students who have not previously earned a bachelor’s or first professional degree. Priority is given to Pell Grant recipients who have the lowest expected family contributions. The institution decides the amount of the grant, which can be up to $4,000 but not less than $100, for an academic year (34 CFR 676.10 and 676.20). Condition: For certain students identified through our testing, the University did not properly calculate the student’s COA. Additionally, for certain students, the University improperly calculated the student’s Pell award. Furthermore, for certain students, the University awarded and disbursed FSEOG funds in excess of the annual maximum. Finally, the University did not give priority to Federal Pell Grant recipients when awarding and disbursing FSEOG funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students’ COAs, calculate eligible award amounts, and properly award aid in-line with the required guidelines could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: For 4 of 25 students selected for testing, the University did not properly calculate the student’s COA. For 1 of 25 students selected for testing, the University did not properly calculate the student’s Pell award. For 1 of 25 students selected for testing, the University disbursed FSEOG funds in excess of the annual maximum grant allowed. 11 students disbursed FSEOG funds during the year were improperly given priority over Federal Pell Grant recipients. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures, and internal controls to ensure that Title IV aid is properly calculated, awarded, and disbursed, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly. For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs.
Finding 2023-002
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Calculation of Benefits – Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility – Federal Pell Grant (Assistance Listing 84.063) – Each year, based on the maximum Pell Grant established by Congress, the ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (“EFC”) and COA. The Disbursement Schedules are used to determine annual awards for full time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student’s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. E. Eligibility – Federal Supplemental Educational Opportunity Grant (Assistance Listing 84.007) - The FSEOG program provides grants to eligible undergraduate students who have not previously earned a bachelor’s or first professional degree. Priority is given to Pell Grant recipients who have the lowest expected family contributions. The institution decides the amount of the grant, which can be up to $4,000 but not less than $100, for an academic year (34 CFR 676.10 and 676.20). Condition: For certain students identified through our testing, the University did not properly calculate the student’s COA. Additionally, for certain students, the University improperly calculated the student’s Pell award. Furthermore, for certain students, the University awarded and disbursed FSEOG funds in excess of the annual maximum. Finally, the University did not give priority to Federal Pell Grant recipients when awarding and disbursing FSEOG funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students’ COAs, calculate eligible award amounts, and properly award aid in-line with the required guidelines could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: For 4 of 25 students selected for testing, the University did not properly calculate the student’s COA. For 1 of 25 students selected for testing, the University did not properly calculate the student’s Pell award. For 1 of 25 students selected for testing, the University disbursed FSEOG funds in excess of the annual maximum grant allowed. 11 students disbursed FSEOG funds during the year were improperly given priority over Federal Pell Grant recipients. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures, and internal controls to ensure that Title IV aid is properly calculated, awarded, and disbursed, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly. For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs.
Finding 2023-003
Federal Program Information: Federal Pell Grant Program (ALN: 84.063) and Federal Direct Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Financial Reporting – Federal regulations require the University to submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, COA, and the “Academic Start Date” and “Academic End Date”. Institutions must also submit disbursement records to the COD for students no earlier than 7 calendar days prior to the disbursement date, and no later than 15 calendar days after the institution makes a disbursement. Condition: For certain students identified through our testing, errors were identified in key items reported to the COD in student origination records. Additionally, the University failed to report disbursement records for certain students within the required timeframe. Cause: Administrative oversight with respect to accurate reporting of federal award information. Effect or Potential Effect: The University was not in compliance with COD reporting requirements. Questioned Costs: None. Context: We noted the following exceptions: For 5 of 25 students selected for origination record testing, the student’s COA was inaccurately reported within the COD system. For 1 of 25 students selected for origination record testing, the “Academic Start Date” was inaccurately reported. For 2 of 25 students selected for disbursement record testing, the University waited more than 15 days after making a disbursement of funds to report the required disbursement information. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its procedures to ensure origination and disbursement records are reported accurately and timely to the COD for Federal Direct Loan Program and Federal Pell Grant Program recipients, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual to an automated review process. The COA data that was inputted at the beginning of the award year did not match all budget components causing inaccuracies. The Financial Aid office was adjusting the budget components of the COA manually, which resulted in miscalculations. When these calculations were performed COD might not have been updated and therefore the COA could be inaccurately reported. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes. The Financial Aid office will review all student COA calculations to ensure that the COA used for originating and disbursing funds is correct. The Financial Aid office will set up automatic processing of key reports to identify rejected origination records. The Financial Aid office will set up the Direct Loan COD Reject Report (DCRR) and the Pell COD Reject Report (PCRR) to run Sunday night and be available Monday morning to be reviewed by the Financial Aid Advisors. The Financial Aid office will make the necessary corrections and update by the end of the week. The Financial Aid office will run Batch FA Transmittal Register (FATR) to confirm that all anticipated awards have passed all rules and are ready to transmit. Those that don’t pass will be reviewed and students will be contacted for updated/corrected information. COD records will be exported nightly through an automated process to ensure all deadlines are met and that we are not exceeding the 15 calendar day limit. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which will eliminate the need for any manual calculations of COA. This automated process should eliminate improperly calculated COAs.
Finding 2023-003
Federal Program Information: Federal Pell Grant Program (ALN: 84.063) and Federal Direct Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Financial Reporting – Federal regulations require the University to submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, COA, and the “Academic Start Date” and “Academic End Date”. Institutions must also submit disbursement records to the COD for students no earlier than 7 calendar days prior to the disbursement date, and no later than 15 calendar days after the institution makes a disbursement. Condition: For certain students identified through our testing, errors were identified in key items reported to the COD in student origination records. Additionally, the University failed to report disbursement records for certain students within the required timeframe. Cause: Administrative oversight with respect to accurate reporting of federal award information. Effect or Potential Effect: The University was not in compliance with COD reporting requirements. Questioned Costs: None. Context: We noted the following exceptions: For 5 of 25 students selected for origination record testing, the student’s COA was inaccurately reported within the COD system. For 1 of 25 students selected for origination record testing, the “Academic Start Date” was inaccurately reported. For 2 of 25 students selected for disbursement record testing, the University waited more than 15 days after making a disbursement of funds to report the required disbursement information. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its procedures to ensure origination and disbursement records are reported accurately and timely to the COD for Federal Direct Loan Program and Federal Pell Grant Program recipients, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual to an automated review process. The COA data that was inputted at the beginning of the award year did not match all budget components causing inaccuracies. The Financial Aid office was adjusting the budget components of the COA manually, which resulted in miscalculations. When these calculations were performed COD might not have been updated and therefore the COA could be inaccurately reported. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes. The Financial Aid office will review all student COA calculations to ensure that the COA used for originating and disbursing funds is correct. The Financial Aid office will set up automatic processing of key reports to identify rejected origination records. The Financial Aid office will set up the Direct Loan COD Reject Report (DCRR) and the Pell COD Reject Report (PCRR) to run Sunday night and be available Monday morning to be reviewed by the Financial Aid Advisors. The Financial Aid office will make the necessary corrections and update by the end of the week. The Financial Aid office will run Batch FA Transmittal Register (FATR) to confirm that all anticipated awards have passed all rules and are ready to transmit. Those that don’t pass will be reviewed and students will be contacted for updated/corrected information. COD records will be exported nightly through an automated process to ensure all deadlines are met and that we are not exceeding the 15 calendar day limit. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which will eliminate the need for any manual calculations of COA. This automated process should eliminate improperly calculated COAs.
Finding 2023-004
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Special Reporting – The Fiscal Operations Report and Application to Participate (“FISAP”) is an electronic report submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Key line items containing critical information include: Part I, Identifying Information, Certification, and Warning; Part II, Application to Participate (selected sections); Part III, Fiscal Operations Report, Part IV, Fiscal Operations Report Federal Supplemental Educational Opportunity Grant Program; Part V, Fiscal Operations Report Federal Work-Study Program; and Part VI, Program Summary for Award Year. The FISAP must be submitted each year by the deadline established by the ED. Condition: The University was unable to provide supporting documentation for certain key line items of the submitted FISAP. Cause: Administrative oversight with respect to FISAP reporting. Effect or Potential Effect: The University is not in compliance with FISAP reporting requirements. Failure to report accurate records of expenditures for the previous award year could impact future availability of Title IV aid. Questioned Costs: None. Context: The University was unable to reproduce the reports used to prepare Part VI, Section A of the FISAP. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-002 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies and procedures to ensure that reports used to prepare the annual FISAP are retained, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: After running the FISAP required reports in Colleague, the Financial Aid office will be required to save the reports so they are available to be used as supporting documents. This past year after the data was collected and the reports ran in Colleague the reports were not saved to the network drive and were lost. The reports cannot be recreated at a later date.
Finding 2023-004
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Special Reporting – The Fiscal Operations Report and Application to Participate (“FISAP”) is an electronic report submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Key line items containing critical information include: Part I, Identifying Information, Certification, and Warning; Part II, Application to Participate (selected sections); Part III, Fiscal Operations Report, Part IV, Fiscal Operations Report Federal Supplemental Educational Opportunity Grant Program; Part V, Fiscal Operations Report Federal Work-Study Program; and Part VI, Program Summary for Award Year. The FISAP must be submitted each year by the deadline established by the ED. Condition: The University was unable to provide supporting documentation for certain key line items of the submitted FISAP. Cause: Administrative oversight with respect to FISAP reporting. Effect or Potential Effect: The University is not in compliance with FISAP reporting requirements. Failure to report accurate records of expenditures for the previous award year could impact future availability of Title IV aid. Questioned Costs: None. Context: The University was unable to reproduce the reports used to prepare Part VI, Section A of the FISAP. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-002 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies and procedures to ensure that reports used to prepare the annual FISAP are retained, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: After running the FISAP required reports in Colleague, the Financial Aid office will be required to save the reports so they are available to be used as supporting documents. This past year after the data was collected and the reports ran in Colleague the reports were not saved to the network drive and were lost. The reports cannot be recreated at a later date.
Finding 2023-005
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. Cause: Administrative oversight and lack of sufficient internal controls with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Sampled questioned costs: $3,645; total questioned costs: indeterminable. Context: For 4 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations. Views of Responsible Officials and Planned Corrective Actions: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors in verifying certain data when performing verification. The previous Financial Aid Director was terminated before the prior corrective action plan could be completed. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will implement a Quality Assurance two-step verification process. The financial aid advisor will work with the student to gather necessary documents and perform the original verification. The Associate Director of Financial Aid will review these verifications and update them in Colleague to be transmitted to COD for corrections if needed. The Financial Aid office will run a report to identify all students selected for verification for 2023-2024 and review them for accuracy. If any corrections are needed they will be updated and awards will be adjusted as needed.
Finding 2023-005
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. Cause: Administrative oversight and lack of sufficient internal controls with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Sampled questioned costs: $3,645; total questioned costs: indeterminable. Context: For 4 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations. Views of Responsible Officials and Planned Corrective Actions: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors in verifying certain data when performing verification. The previous Financial Aid Director was terminated before the prior corrective action plan could be completed. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will implement a Quality Assurance two-step verification process. The financial aid advisor will work with the student to gather necessary documents and perform the original verification. The Associate Director of Financial Aid will review these verifications and update them in Colleague to be transmitted to COD for corrections if needed. The Financial Aid office will run a report to identify all students selected for verification for 2023-2024 and review them for accuracy. If any corrections are needed they will be updated and awards will be adjusted as needed.
Finding 2023-005
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. Cause: Administrative oversight and lack of sufficient internal controls with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Sampled questioned costs: $3,645; total questioned costs: indeterminable. Context: For 4 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations. Views of Responsible Officials and Planned Corrective Actions: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors in verifying certain data when performing verification. The previous Financial Aid Director was terminated before the prior corrective action plan could be completed. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will implement a Quality Assurance two-step verification process. The financial aid advisor will work with the student to gather necessary documents and perform the original verification. The Associate Director of Financial Aid will review these verifications and update them in Colleague to be transmitted to COD for corrections if needed. The Financial Aid office will run a report to identify all students selected for verification for 2023-2024 and review them for accuracy. If any corrections are needed they will be updated and awards will be adjusted as needed.
Finding 2023-005
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. Cause: Administrative oversight and lack of sufficient internal controls with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Sampled questioned costs: $3,645; total questioned costs: indeterminable. Context: For 4 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations. Views of Responsible Officials and Planned Corrective Actions: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors in verifying certain data when performing verification. The previous Financial Aid Director was terminated before the prior corrective action plan could be completed. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will implement a Quality Assurance two-step verification process. The financial aid advisor will work with the student to gather necessary documents and perform the original verification. The Associate Director of Financial Aid will review these verifications and update them in Colleague to be transmitted to COD for corrections if needed. The Financial Aid office will run a report to identify all students selected for verification for 2023-2024 and review them for accuracy. If any corrections are needed they will be updated and awards will be adjusted as needed.
Finding 2023-006
Federal Program Information: Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements To or On Behalf of Students – Federal Work Study – Before an institution makes an initial disbursement of FWS compensation to a student for an award period, the institution must notify the student of the amount of funds the student is authorized to earn, and how and when the FWS compensation will be paid (34 CFR 675.16(a)(3)). The institution must also establish and maintain program and fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day (34 CFR 675.19(b)(2)(i)). Condition: For certain students selected for testing, the University was unable to support that students were notified of the terms of their award prior to disbursing FWS compensation. Cause: Administrative oversight with respect to FWS compensation. Effect: Students were not properly notified of the terms and conditions of their FWS compensation in accordance with federal regulations. Questioned Costs: None. Context: For 4 of 13 students selected for testing, the University was unable to provide documentation supporting that students were properly notified of the terms and conditions of their FWS compensation. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures over FWS compensation to ensure that students are properly notified of the terms of their compensation. Views of Responsible Officials and Planned Corrective Actions: In an effort to maximize the utilization of student aid, current student workers were reviewed for FWS eligibility. Those students identified were awarded the FWS funds without being notified though they did indicate they were interested in FWS funds. The Financial Aid Office and Human Resources will collaborate to ensure that work study students are not allowed to start work until they have followed proper hiring procedures within the PeopleAdmin system. The Financial Aid office is also modifying the way this award will be offered in 2024-2025. The Financial Aid office will add this award to the automated process when students are first packaged. At that time, they will need to accept or decline the offer. From acceptance, the student will be prompted to complete a short training video on acquiring a University job. Upon completion of the video the students will be provided an automated link to the PeopleAdmin system where they will have access to the open jobs on campus. The Financial Aid office will receive an automated confirmation from the PeopleAdmin system that all necessary documents and training have been completed. The Financial Aid office will assign an individual to oversee this process.
Finding 2023-007
Federal Program Information: Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account. Condition: Certain borrowers did not receive a loan disbursement notification, or the University was unable to provide a copy of the loan disbursement notification sent to the student. Cause: Administrative oversight with respect to loan disbursement notifications. Effect: Students and/or parents were not properly notified of loan disbursements and/or their right to cancel/decline loan awards. Questioned Costs: None. Context: For 2 of 40 students selected for testing, the University was unable to provide documentation supporting appropriate loan disbursement notification. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-004 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures over loan disbursement notifications to ensure that such notifications are sent to student and/or parent borrowers within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: The Financial Aid office made several staffing changes in 2022-2023. The loan coordinator left the institution. Newly hired staff were not properly trained, resulting in the failure to carry out loan notification as required. The VP of Enrollment created a process, implemented in the Spring of 2023, that automated the student loan disbursement notifications with-in the required 30 days of student accounts transmitting their loans.
Finding 2023-008
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard termbased institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amounts to be returned to the ED. Additionally, the University was unable to provide evidence of approval from the borrower prior to making a post-withdrawal disbursement of loan funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to return of Title IV fund calculations and post-withdrawal disbursements. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Sampled questioned costs: $12,572; total questioned costs: indeterminable. Context: For 3 of 5 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. Additionally, funds due for return were either not returned or were not returned timely for 3 of 5 students. For 1 of 5 students selected for testing, the University did not retain documentation of the student’s or parent’s approval obtained prior to making a post-withdrawal disbursement of loan funds. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-005 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, and that adequate records are maintained to support proper procedures for post-withdrawal disbursements. Views of Responsible Officials and Planned Corrective Actions: The Financial Aid office made several staffing changes in 2022-2023. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, has developed an automated weekly report confirming student withdrawal dates. The report is scheduled to be emailed to Financial Aid office every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of title IV funds calculation would be performed for those students. Any funds required to be disbursed or returned would then be processed.
Finding 2023-008
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard termbased institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amounts to be returned to the ED. Additionally, the University was unable to provide evidence of approval from the borrower prior to making a post-withdrawal disbursement of loan funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to return of Title IV fund calculations and post-withdrawal disbursements. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Sampled questioned costs: $12,572; total questioned costs: indeterminable. Context: For 3 of 5 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. Additionally, funds due for return were either not returned or were not returned timely for 3 of 5 students. For 1 of 5 students selected for testing, the University did not retain documentation of the student’s or parent’s approval obtained prior to making a post-withdrawal disbursement of loan funds. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-005 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, and that adequate records are maintained to support proper procedures for post-withdrawal disbursements. Views of Responsible Officials and Planned Corrective Actions: The Financial Aid office made several staffing changes in 2022-2023. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, has developed an automated weekly report confirming student withdrawal dates. The report is scheduled to be emailed to Financial Aid office every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of title IV funds calculation would be performed for those students. Any funds required to be disbursed or returned would then be processed.
Finding 2023-008
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard termbased institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amounts to be returned to the ED. Additionally, the University was unable to provide evidence of approval from the borrower prior to making a post-withdrawal disbursement of loan funds. Cause: Administrative oversight and lack of sufficient internal controls with respect to return of Title IV fund calculations and post-withdrawal disbursements. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Sampled questioned costs: $12,572; total questioned costs: indeterminable. Context: For 3 of 5 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. Additionally, funds due for return were either not returned or were not returned timely for 3 of 5 students. For 1 of 5 students selected for testing, the University did not retain documentation of the student’s or parent’s approval obtained prior to making a post-withdrawal disbursement of loan funds. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-005 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, and that adequate records are maintained to support proper procedures for post-withdrawal disbursements. Views of Responsible Officials and Planned Corrective Actions: The Financial Aid office made several staffing changes in 2022-2023. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, has developed an automated weekly report confirming student withdrawal dates. The report is scheduled to be emailed to Financial Aid office every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of title IV funds calculation would be performed for those students. Any funds required to be disbursed or returned would then be processed.
Finding 2023-009
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: The University did not accurately report certain significant data elements to the NSLDS website for certain students who graduated, withdrew, or had an increase/decrease in attendance level during the year. Additionally, the University’s fiscal year SCHER1 report included multiple instances in which error records were not corrected within the required timeframe. Cause: Administrative oversight with respect to enrollment reporting compliance requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions as a result of our procedures: For 3 of 25 students sampled whose status changed during the year, the University failed to accurately report all significant data elements under the Program-Level Record in a timely notification to the NSLDS website. For 4 of 5 Error Reports tested, error records identified in the Error/Acknowledgment files were not corrected within the required timeframe. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University Registrar will develop a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions in the Registrar's Office. Enrollment reporting is a critical function that will be prioritized in the implementation of the referenced plan.
Finding 2023-009
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: The University did not accurately report certain significant data elements to the NSLDS website for certain students who graduated, withdrew, or had an increase/decrease in attendance level during the year. Additionally, the University’s fiscal year SCHER1 report included multiple instances in which error records were not corrected within the required timeframe. Cause: Administrative oversight with respect to enrollment reporting compliance requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions as a result of our procedures: For 3 of 25 students sampled whose status changed during the year, the University failed to accurately report all significant data elements under the Program-Level Record in a timely notification to the NSLDS website. For 4 of 5 Error Reports tested, error records identified in the Error/Acknowledgment files were not corrected within the required timeframe. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University Registrar will develop a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions in the Registrar's Office. Enrollment reporting is a critical function that will be prioritized in the implementation of the referenced plan.