Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and “alert” the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19).
Condition: A transfer student was not added to the Transfer Monitoring List.
Cause: Administrative oversight.
Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 1 of 8 students sampled, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-003.
Recommendation: We recommend the University enhance its procedures to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy.
Federal Program Information: Federal Supplemental Education 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 Test and Provisions – Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn.
Condition: Students’ return calculations were not accurately prepared due to improper inclusion of institutionally scheduled breaks.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: Over or underpayment of Title IV funds.
Questioned Costs: None.
Context: For 2 of 4 students tested, the amounts to return were not calculated in accordance with the requirements.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The break days for fall 2022 were not properly calculated to include a break of 5 days. We will develop and implement a process within Student Financial Services to audit all R2T4 records for accuracy, completeness, and consistency regarding length of academic periods.
Federal Program Information: Federal Work-Study Program (ALN 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 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 tolerance is allowed 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: An instance was identified where funds drawn were held in excess of the allowable time frame.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with Cash Management requirements.
Questioned Costs: None.
Context: An early draw of the University’s 21-22 award year carry-forward resulted in excess cash that was not eliminated timely.
Identification as a Repeat Finding: There was no similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures to ensure that excess cash is returned timely.
Views of Responsible Officials:
Cash management of Title IV funds at the University is generally performed only on a reimbursement basis. In this situation there was a one-time error in calculating available FWS funds and year-to-date FWS earnings such that approximately $11,000 in excess cash was received near the end of the 21-22 year and then carried forward. The error was discovered early in 22-23 but by that point earnings had outpaced cash on hand and so no effort was made to return funds. A new procedure with a multi-year workbook has been established for monitoring FWS earnings across award periods to prevent a repeat occurrence.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and “alert” the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19).
Condition: A transfer student was not added to the Transfer Monitoring List.
Cause: Administrative oversight.
Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 1 of 8 students sampled, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-003.
Recommendation: We recommend the University enhance its procedures to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and “alert” the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19).
Condition: A transfer student was not added to the Transfer Monitoring List.
Cause: Administrative oversight.
Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 1 of 8 students sampled, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-003.
Recommendation: We recommend the University enhance its procedures to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy.
Federal Program Information: Federal Supplemental Education 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 Test and Provisions – Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn.
Condition: Students’ return calculations were not accurately prepared due to improper inclusion of institutionally scheduled breaks.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: Over or underpayment of Title IV funds.
Questioned Costs: None.
Context: For 2 of 4 students tested, the amounts to return were not calculated in accordance with the requirements.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The break days for fall 2022 were not properly calculated to include a break of 5 days. We will develop and implement a process within Student Financial Services to audit all R2T4 records for accuracy, completeness, and consistency regarding length of academic periods.
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 – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: Certain students’ program-level enrollment data was not accurately reported.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 5 of 40 program level records tested, the students’ program begin date was not accurately reported.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-001.
Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure that program-level enrollment data is timely and accurately reported to NSLDS.
Views of Responsible Officials: The Registrar’s Office will reach out to Jenzabar to determine what is triggering the incorrect program start date. Beginning with the summer 2024 students, each new student record will be reviewed prior to the initial National Student Clearinghouse submission to ensure that the start date is being reported correctly.
Federal Program Information: Federal Direct Student Loans (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 Notifications: 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 U.S. Department of Education; 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: Records showing that a loan disbursement notification was sent were not retained for a certain student.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with loan notification requirements.
Questioned Costs: None.
Context: For 1 of 25 Direct Loan disbursements tested, the University was unable to provide documentation showing that a notification was sent to the borrower.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures over loan notifications to ensure timely and accurate notification to borrowers.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A loan disbursement notification was sent to the student for both the fall 2022 and spring 2023 semesters. We can document the spring 2023 loan disbursement notification was sent but are unable to document the date. Our internal processes dictate that the notification would normally be sent on the date of disbursement. We will develop and implement additional controls to effectively capture a student’s disbursement notification to ensure that both a record of the notification and the date are maintained.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and “alert” the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19).
Condition: A transfer student was not added to the Transfer Monitoring List.
Cause: Administrative oversight.
Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 1 of 8 students sampled, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-003.
Recommendation: We recommend the University enhance its procedures to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy.
Federal Program Information: Federal Supplemental Education 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 Test and Provisions – Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn.
Condition: Students’ return calculations were not accurately prepared due to improper inclusion of institutionally scheduled breaks.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: Over or underpayment of Title IV funds.
Questioned Costs: None.
Context: For 2 of 4 students tested, the amounts to return were not calculated in accordance with the requirements.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The break days for fall 2022 were not properly calculated to include a break of 5 days. We will develop and implement a process within Student Financial Services to audit all R2T4 records for accuracy, completeness, and consistency regarding length of academic periods.
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 – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: Certain students’ program-level enrollment data was not accurately reported.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 5 of 40 program level records tested, the students’ program begin date was not accurately reported.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-001.
Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure that program-level enrollment data is timely and accurately reported to NSLDS.
Views of Responsible Officials: The Registrar’s Office will reach out to Jenzabar to determine what is triggering the incorrect program start date. Beginning with the summer 2024 students, each new student record will be reviewed prior to the initial National Student Clearinghouse submission to ensure that the start date is being reported correctly.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and “alert” the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19).
Condition: A transfer student was not added to the Transfer Monitoring List.
Cause: Administrative oversight.
Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 1 of 8 students sampled, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-003.
Recommendation: We recommend the University enhance its procedures to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy.
Federal Program Information: Federal Supplemental Education 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 Test and Provisions – Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn.
Condition: Students’ return calculations were not accurately prepared due to improper inclusion of institutionally scheduled breaks.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: Over or underpayment of Title IV funds.
Questioned Costs: None.
Context: For 2 of 4 students tested, the amounts to return were not calculated in accordance with the requirements.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The break days for fall 2022 were not properly calculated to include a break of 5 days. We will develop and implement a process within Student Financial Services to audit all R2T4 records for accuracy, completeness, and consistency regarding length of academic periods.
Federal Program Information: Federal Work-Study Program (ALN 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 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 tolerance is allowed 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: An instance was identified where funds drawn were held in excess of the allowable time frame.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with Cash Management requirements.
Questioned Costs: None.
Context: An early draw of the University’s 21-22 award year carry-forward resulted in excess cash that was not eliminated timely.
Identification as a Repeat Finding: There was no similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures to ensure that excess cash is returned timely.
Views of Responsible Officials:
Cash management of Title IV funds at the University is generally performed only on a reimbursement basis. In this situation there was a one-time error in calculating available FWS funds and year-to-date FWS earnings such that approximately $11,000 in excess cash was received near the end of the 21-22 year and then carried forward. The error was discovered early in 22-23 but by that point earnings had outpaced cash on hand and so no effort was made to return funds. A new procedure with a multi-year workbook has been established for monitoring FWS earnings across award periods to prevent a repeat occurrence.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and “alert” the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19).
Condition: A transfer student was not added to the Transfer Monitoring List.
Cause: Administrative oversight.
Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 1 of 8 students sampled, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-003.
Recommendation: We recommend the University enhance its procedures to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and “alert” the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19).
Condition: A transfer student was not added to the Transfer Monitoring List.
Cause: Administrative oversight.
Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 1 of 8 students sampled, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-003.
Recommendation: We recommend the University enhance its procedures to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy.
Federal Program Information: Federal Supplemental Education 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 Test and Provisions – Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn.
Condition: Students’ return calculations were not accurately prepared due to improper inclusion of institutionally scheduled breaks.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: Over or underpayment of Title IV funds.
Questioned Costs: None.
Context: For 2 of 4 students tested, the amounts to return were not calculated in accordance with the requirements.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The break days for fall 2022 were not properly calculated to include a break of 5 days. We will develop and implement a process within Student Financial Services to audit all R2T4 records for accuracy, completeness, and consistency regarding length of academic periods.
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 – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: Certain students’ program-level enrollment data was not accurately reported.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 5 of 40 program level records tested, the students’ program begin date was not accurately reported.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-001.
Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure that program-level enrollment data is timely and accurately reported to NSLDS.
Views of Responsible Officials: The Registrar’s Office will reach out to Jenzabar to determine what is triggering the incorrect program start date. Beginning with the summer 2024 students, each new student record will be reviewed prior to the initial National Student Clearinghouse submission to ensure that the start date is being reported correctly.
Federal Program Information: Federal Direct Student Loans (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 Notifications: 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 U.S. Department of Education; 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: Records showing that a loan disbursement notification was sent were not retained for a certain student.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with loan notification requirements.
Questioned Costs: None.
Context: For 1 of 25 Direct Loan disbursements tested, the University was unable to provide documentation showing that a notification was sent to the borrower.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures over loan notifications to ensure timely and accurate notification to borrowers.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A loan disbursement notification was sent to the student for both the fall 2022 and spring 2023 semesters. We can document the spring 2023 loan disbursement notification was sent but are unable to document the date. Our internal processes dictate that the notification would normally be sent on the date of disbursement. We will develop and implement additional controls to effectively capture a student’s disbursement notification to ensure that both a record of the notification and the date are maintained.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and “alert” the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19).
Condition: A transfer student was not added to the Transfer Monitoring List.
Cause: Administrative oversight.
Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 1 of 8 students sampled, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-003.
Recommendation: We recommend the University enhance its procedures to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy.
Federal Program Information: Federal Supplemental Education 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 Test and Provisions – Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn.
Condition: Students’ return calculations were not accurately prepared due to improper inclusion of institutionally scheduled breaks.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: Over or underpayment of Title IV funds.
Questioned Costs: None.
Context: For 2 of 4 students tested, the amounts to return were not calculated in accordance with the requirements.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The break days for fall 2022 were not properly calculated to include a break of 5 days. We will develop and implement a process within Student Financial Services to audit all R2T4 records for accuracy, completeness, and consistency regarding length of academic periods.
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 – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: Certain students’ program-level enrollment data was not accurately reported.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 5 of 40 program level records tested, the students’ program begin date was not accurately reported.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-001.
Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure that program-level enrollment data is timely and accurately reported to NSLDS.
Views of Responsible Officials: The Registrar’s Office will reach out to Jenzabar to determine what is triggering the incorrect program start date. Beginning with the summer 2024 students, each new student record will be reviewed prior to the initial National Student Clearinghouse submission to ensure that the start date is being reported correctly.