Criteria or specific requirement: 34 CFR 600.2 defines academic engagement as including; (1) attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students, (2) submitting an academic assignment, (3) taking an assessment or an exam, (4) participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction, (5) participating in a study group, group project, or an online discussion that is assigned by the institution, or (6) interacting with an instructor about academic matters. A school must monitor academic engagement for students enrolled in distance education courses to accurately determine the date in which a student stopped performing academically participating activities and therefore withdrew from a course.
Condition: The University did not have proper documentation that supported academic engagement by four students as outlined in 34 CFR 600.2.
Questioned costs: None.
Context: We tested 60 students that withdrew from the University during the fiscal year to determine the University’s compliance with return of Title IV funds. Of the 60 students that were selected, 44 students were determined to have been enrolled in online courses offered by the University. We noted four students lacked supporting documentation for academic engagement as outlined in 34 CFR 600.2.
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with academic engagement monitoring requirements.
Effect: Proper monitoring of the academic engagement of students enrolled in distance education courses allows the University to accurately determine the date in which a student withdrew from the University. Without proper monitoring in place, the University may be using inaccurate withdrawal dates to perform its return of Title IV calculations.
Repeat Finding: No
Recommendation: We recommend that the University strengthen its internal controls over monitoring the academic engagement for students that are enrolled in distance education courses at the University.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 690.83(b)(2) and 685.309, an institution must report any enrollment status changes, including the date of the change per the institution’s reporting system, to the National Student Loan Data System (NSLDS) for participating students within 60 days of the change.
Condition: As part of the March 4, 2023, roster submission of enrollment status changes, the University reported an effective enrollment status change of February 20, 2023 for a student who received both a Federal Pell Grant and Direct Student Loans during the fiscal year. Per the University’s records, the student had withdrawn from the University on February 4, 2023. The University incorrectly reported the effective enrollment status change to NSLDS.
Questioned costs: None.
Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment effective date per the University’s records did not agree to the enrollment effective date that was reported to NSLDS.
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Title IV Student Financial Aid program.
Effect: Enrollment reporting assists lenders in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status.
Repeat finding: No
Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates reported to NSLDS agree to the enrollment effective dates per the University’s records.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: 34 CFR 600.2 defines academic engagement as including; (1) attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students, (2) submitting an academic assignment, (3) taking an assessment or an exam, (4) participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction, (5) participating in a study group, group project, or an online discussion that is assigned by the institution, or (6) interacting with an instructor about academic matters. A school must monitor academic engagement for students enrolled in distance education courses to accurately determine the date in which a student stopped performing academically participating activities and therefore withdrew from a course.
Condition: The University did not have proper documentation that supported academic engagement by four students as outlined in 34 CFR 600.2.
Questioned costs: None.
Context: We tested 60 students that withdrew from the University during the fiscal year to determine the University’s compliance with return of Title IV funds. Of the 60 students that were selected, 44 students were determined to have been enrolled in online courses offered by the University. We noted four students lacked supporting documentation for academic engagement as outlined in 34 CFR 600.2.
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with academic engagement monitoring requirements.
Effect: Proper monitoring of the academic engagement of students enrolled in distance education courses allows the University to accurately determine the date in which a student withdrew from the University. Without proper monitoring in place, the University may be using inaccurate withdrawal dates to perform its return of Title IV calculations.
Repeat Finding: No
Recommendation: We recommend that the University strengthen its internal controls over monitoring the academic engagement for students that are enrolled in distance education courses at the University.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 685.304(a)(1), a school must ensure that entrance counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan student borrower prior to making the first disbursement of the proceeds of a loan to a student borrower unless the student borrower has received a prior Direct Subsidized Loan, Direct Unsubsidized Loan, Subsidized or Unsubsidized Federal Stafford Loan, or Federal SLS Loan.
Condition: The University made the first disbursement of proceeds of a Direct Subsidized Loan and a Direct Unsubsidized Loan to a student borrower on October 4, 2022 but conducted entrance counseling for the student borrower on February 21, 2024. The University’s processes and internal controls did not detect this instance of noncompliance.
Context: We tested 45 students that were disbursed a Direct Subsidized Loan and/or a Direct Unsubsidized Loan during the fiscal year to determine the University’s compliance with counseling borrowers requirements as outlined by the Department of Education and noted one student was disbursed Direct Loans prior to the University ensuring that the student borrower had completed the required entrance counseling.
Questioned costs: $7,500. Assistance Listing Number: 84.268
Cause: The student had completed course work at another school prior to enrollment at the University, however the University failed to ensure and/or retain documentation that the student had completed entrance counseling prior to disbursing the student proceeds of a Direct Subsidized and Direct Unsubsidized Loan.
Effect: The University is not in compliance with counseling borrowers requirements.
Repeat Finding: No.
Recommendation: We recommend that the University implement processes and/or internal controls that ensure that a student has completed entrance counseling prior to disbursing Direct Loans proceeds.
Views of responsible officials: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 690.83(b)(2) and 685.309, an institution must report any enrollment status changes, including the date of the change per the institution’s reporting system, to the National Student Loan Data System (NSLDS) for participating students within 60 days of the change.
Condition: As part of the March 4, 2023, roster submission of enrollment status changes, the University reported an effective enrollment status change of February 20, 2023 for a student who received both a Federal Pell Grant and Direct Student Loans during the fiscal year. Per the University’s records, the student had withdrawn from the University on February 4, 2023. The University incorrectly reported the effective enrollment status change to NSLDS.
Questioned costs: None.
Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment effective date per the University’s records did not agree to the enrollment effective date that was reported to NSLDS.
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Title IV Student Financial Aid program.
Effect: Enrollment reporting assists lenders in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status.
Repeat finding: No
Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates reported to NSLDS agree to the enrollment effective dates per the University’s records.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: 34 CFR 600.2 defines academic engagement as including; (1) attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students, (2) submitting an academic assignment, (3) taking an assessment or an exam, (4) participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction, (5) participating in a study group, group project, or an online discussion that is assigned by the institution, or (6) interacting with an instructor about academic matters. A school must monitor academic engagement for students enrolled in distance education courses to accurately determine the date in which a student stopped performing academically participating activities and therefore withdrew from a course.
Condition: The University did not have proper documentation that supported academic engagement by four students as outlined in 34 CFR 600.2.
Questioned costs: None.
Context: We tested 60 students that withdrew from the University during the fiscal year to determine the University’s compliance with return of Title IV funds. Of the 60 students that were selected, 44 students were determined to have been enrolled in online courses offered by the University. We noted four students lacked supporting documentation for academic engagement as outlined in 34 CFR 600.2.
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with academic engagement monitoring requirements.
Effect: Proper monitoring of the academic engagement of students enrolled in distance education courses allows the University to accurately determine the date in which a student withdrew from the University. Without proper monitoring in place, the University may be using inaccurate withdrawal dates to perform its return of Title IV calculations.
Repeat Finding: No
Recommendation: We recommend that the University strengthen its internal controls over monitoring the academic engagement for students that are enrolled in distance education courses at the University.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: 34 CFR 600.2 defines academic engagement as including; (1) attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students, (2) submitting an academic assignment, (3) taking an assessment or an exam, (4) participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction, (5) participating in a study group, group project, or an online discussion that is assigned by the institution, or (6) interacting with an instructor about academic matters. A school must monitor academic engagement for students enrolled in distance education courses to accurately determine the date in which a student stopped performing academically participating activities and therefore withdrew from a course.
Condition: The University did not have proper documentation that supported academic engagement by four students as outlined in 34 CFR 600.2.
Questioned costs: None.
Context: We tested 60 students that withdrew from the University during the fiscal year to determine the University’s compliance with return of Title IV funds. Of the 60 students that were selected, 44 students were determined to have been enrolled in online courses offered by the University. We noted four students lacked supporting documentation for academic engagement as outlined in 34 CFR 600.2.
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with academic engagement monitoring requirements.
Effect: Proper monitoring of the academic engagement of students enrolled in distance education courses allows the University to accurately determine the date in which a student withdrew from the University. Without proper monitoring in place, the University may be using inaccurate withdrawal dates to perform its return of Title IV calculations.
Repeat Finding: No
Recommendation: We recommend that the University strengthen its internal controls over monitoring the academic engagement for students that are enrolled in distance education courses at the University.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 690.83(b)(2) and 685.309, an institution must report any enrollment status changes, including the date of the change per the institution’s reporting system, to the National Student Loan Data System (NSLDS) for participating students within 60 days of the change.
Condition: As part of the March 4, 2023, roster submission of enrollment status changes, the University reported an effective enrollment status change of February 20, 2023 for a student who received both a Federal Pell Grant and Direct Student Loans during the fiscal year. Per the University’s records, the student had withdrawn from the University on February 4, 2023. The University incorrectly reported the effective enrollment status change to NSLDS.
Questioned costs: None.
Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment effective date per the University’s records did not agree to the enrollment effective date that was reported to NSLDS.
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Title IV Student Financial Aid program.
Effect: Enrollment reporting assists lenders in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status.
Repeat finding: No
Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates reported to NSLDS agree to the enrollment effective dates per the University’s records.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: 34 CFR 600.2 defines academic engagement as including; (1) attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students, (2) submitting an academic assignment, (3) taking an assessment or an exam, (4) participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction, (5) participating in a study group, group project, or an online discussion that is assigned by the institution, or (6) interacting with an instructor about academic matters. A school must monitor academic engagement for students enrolled in distance education courses to accurately determine the date in which a student stopped performing academically participating activities and therefore withdrew from a course.
Condition: The University did not have proper documentation that supported academic engagement by four students as outlined in 34 CFR 600.2.
Questioned costs: None.
Context: We tested 60 students that withdrew from the University during the fiscal year to determine the University’s compliance with return of Title IV funds. Of the 60 students that were selected, 44 students were determined to have been enrolled in online courses offered by the University. We noted four students lacked supporting documentation for academic engagement as outlined in 34 CFR 600.2.
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with academic engagement monitoring requirements.
Effect: Proper monitoring of the academic engagement of students enrolled in distance education courses allows the University to accurately determine the date in which a student withdrew from the University. Without proper monitoring in place, the University may be using inaccurate withdrawal dates to perform its return of Title IV calculations.
Repeat Finding: No
Recommendation: We recommend that the University strengthen its internal controls over monitoring the academic engagement for students that are enrolled in distance education courses at the University.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 685.304(a)(1), a school must ensure that entrance counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan student borrower prior to making the first disbursement of the proceeds of a loan to a student borrower unless the student borrower has received a prior Direct Subsidized Loan, Direct Unsubsidized Loan, Subsidized or Unsubsidized Federal Stafford Loan, or Federal SLS Loan.
Condition: The University made the first disbursement of proceeds of a Direct Subsidized Loan and a Direct Unsubsidized Loan to a student borrower on October 4, 2022 but conducted entrance counseling for the student borrower on February 21, 2024. The University’s processes and internal controls did not detect this instance of noncompliance.
Context: We tested 45 students that were disbursed a Direct Subsidized Loan and/or a Direct Unsubsidized Loan during the fiscal year to determine the University’s compliance with counseling borrowers requirements as outlined by the Department of Education and noted one student was disbursed Direct Loans prior to the University ensuring that the student borrower had completed the required entrance counseling.
Questioned costs: $7,500. Assistance Listing Number: 84.268
Cause: The student had completed course work at another school prior to enrollment at the University, however the University failed to ensure and/or retain documentation that the student had completed entrance counseling prior to disbursing the student proceeds of a Direct Subsidized and Direct Unsubsidized Loan.
Effect: The University is not in compliance with counseling borrowers requirements.
Repeat Finding: No.
Recommendation: We recommend that the University implement processes and/or internal controls that ensure that a student has completed entrance counseling prior to disbursing Direct Loans proceeds.
Views of responsible officials: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 690.83(b)(2) and 685.309, an institution must report any enrollment status changes, including the date of the change per the institution’s reporting system, to the National Student Loan Data System (NSLDS) for participating students within 60 days of the change.
Condition: As part of the March 4, 2023, roster submission of enrollment status changes, the University reported an effective enrollment status change of February 20, 2023 for a student who received both a Federal Pell Grant and Direct Student Loans during the fiscal year. Per the University’s records, the student had withdrawn from the University on February 4, 2023. The University incorrectly reported the effective enrollment status change to NSLDS.
Questioned costs: None.
Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment effective date per the University’s records did not agree to the enrollment effective date that was reported to NSLDS.
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Title IV Student Financial Aid program.
Effect: Enrollment reporting assists lenders in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status.
Repeat finding: No
Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates reported to NSLDS agree to the enrollment effective dates per the University’s records.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: 34 CFR 600.2 defines academic engagement as including; (1) attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students, (2) submitting an academic assignment, (3) taking an assessment or an exam, (4) participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction, (5) participating in a study group, group project, or an online discussion that is assigned by the institution, or (6) interacting with an instructor about academic matters. A school must monitor academic engagement for students enrolled in distance education courses to accurately determine the date in which a student stopped performing academically participating activities and therefore withdrew from a course.
Condition: The University did not have proper documentation that supported academic engagement by four students as outlined in 34 CFR 600.2.
Questioned costs: None.
Context: We tested 60 students that withdrew from the University during the fiscal year to determine the University’s compliance with return of Title IV funds. Of the 60 students that were selected, 44 students were determined to have been enrolled in online courses offered by the University. We noted four students lacked supporting documentation for academic engagement as outlined in 34 CFR 600.2.
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with academic engagement monitoring requirements.
Effect: Proper monitoring of the academic engagement of students enrolled in distance education courses allows the University to accurately determine the date in which a student withdrew from the University. Without proper monitoring in place, the University may be using inaccurate withdrawal dates to perform its return of Title IV calculations.
Repeat Finding: No
Recommendation: We recommend that the University strengthen its internal controls over monitoring the academic engagement for students that are enrolled in distance education courses at the University.
View of responsible official: The University agrees with the finding.