Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022-2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); 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. 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 must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award (2 CFR 200.303).
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). We identified the following items of noncompliance:
8 enrollment changes where a student's enrollment status effective date was not correctly reported to NSLDS. (34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2))
1 instance where a student’s enrollment status change was not reported timely to NSLDS. (34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2))
Questioned costs: None
Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 9 instances with exceptions as described above.
Cause: The University was unaware of the errors which were caused by the transmission of date between their student information system and the third-party servicer.
Effect: The NSLDS system could not be updated accurately or timely with student enrollment information.
Repeat Finding: No
Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to
ensure that reporting is completed accurately and timely.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022-2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); 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. 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 must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award (2 CFR 200.303).
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). We identified the following items of noncompliance:
8 enrollment changes where a student's enrollment status effective date was not correctly reported to NSLDS. (34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2))
1 instance where a student’s enrollment status change was not reported timely to NSLDS. (34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2))
Questioned costs: None
Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 9 instances with exceptions as described above.
Cause: The University was unaware of the errors which were caused by the transmission of date between their student information system and the third-party servicer.
Effect: The NSLDS system could not be updated accurately or timely with student enrollment information.
Repeat Finding: No
Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to
ensure that reporting is completed accurately and timely.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022-2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); 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. 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 must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award (2 CFR 200.303).
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). We identified the following items of noncompliance:
8 enrollment changes where a student's enrollment status effective date was not correctly reported to NSLDS. (34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2))
1 instance where a student’s enrollment status change was not reported timely to NSLDS. (34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2))
Questioned costs: None
Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 9 instances with exceptions as described above.
Cause: The University was unaware of the errors which were caused by the transmission of date between their student information system and the third-party servicer.
Effect: The NSLDS system could not be updated accurately or timely with student enrollment information.
Repeat Finding: No
Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to
ensure that reporting is completed accurately and timely.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.268
Federal Award Identification Number and Year: P268K32067, 2022-2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 34 CFR 668.164(l) requires an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution. Additionally, if a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award (2 CFR 200.303).
Condition: During our testing of outstanding SFA checks, we identified three checks outstanding that had not been returned to the U.S. Department of Education within 240 days.
Questioned costs: None
Context: Out of our population of 31 outstanding checks, we noted three had the exception described above.
Cause: The University did not have a process in place when these checks were created in fiscal year 2021; when a process was created, it was not retroactively applied to all outstanding SFA checks to date.
Effect: The University did not return all SFA funds timely to the Department of Education.
Repeat Finding: No
Recommendation: CLA recommends that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue.
Views of responsible officials: The University agrees with the finding. Management has developed a
plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022- 2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 34 CFR 668.164(e)(2)(viii) requires institutions must provide an upto-date URL for their contract with a third-party servicer who assist in providing credit balances to students. This publication is published in a centralized database accessible to the public managed by the U.S. Department of Education. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303).
Condition: During our testing the University could not provide support that an up-to-date third party servicer contract and the related contract data was provided to the U.S. Department of Education. Additionally, the University was not included within the database retained by the U.S. Department of Education.
Questioned costs: None
Context: The University did not meet the compliance requirement to report the contract and contract components to the U.S. Department of Education.
Cause: The University was not aware of the requirement and previous personnel did not retain applicable support, if completed.
Effect: The U.S. Department of Education was not provided required information regarding the contract.
Repeat Finding: No
Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022- 2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 34 CFR 668.164(e)(2)(viii) requires institutions must provide an upto-date URL for their contract with a third-party servicer who assist in providing credit balances to students. This publication is published in a centralized database accessible to the public managed by the U.S. Department of Education. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303).
Condition: During our testing the University could not provide support that an up-to-date third party servicer contract and the related contract data was provided to the U.S. Department of Education. Additionally, the University was not included within the database retained by the U.S. Department of Education.
Questioned costs: None
Context: The University did not meet the compliance requirement to report the contract and contract components to the U.S. Department of Education.
Cause: The University was not aware of the requirement and previous personnel did not retain applicable support, if completed.
Effect: The U.S. Department of Education was not provided required information regarding the contract.
Repeat Finding: No
Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022- 2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 34 CFR 668.164(e)(2)(viii) requires institutions must provide an upto-date URL for their contract with a third-party servicer who assist in providing credit balances to students. This publication is published in a centralized database accessible to the public managed by the U.S. Department of Education. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303).
Condition: During our testing the University could not provide support that an up-to-date third party servicer contract and the related contract data was provided to the U.S. Department of Education. Additionally, the University was not included within the database retained by the U.S. Department of Education.
Questioned costs: None
Context: The University did not meet the compliance requirement to report the contract and contract components to the U.S. Department of Education.
Cause: The University was not aware of the requirement and previous personnel did not retain applicable support, if completed.
Effect: The U.S. Department of Education was not provided required information regarding the contract.
Repeat Finding: No
Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.038
Federal Award Identification Number and Year: N/A – Revolving Loan Portfolio
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 34 CFR 674.19 (e)(4)(i) requires an institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303).
Condition: During our testing of the open Perkins Loans, we selected a sample of 21 loans, 6 of the loans tested were paper MPNs electronically copied to Adobe PDF and the paper MPNs were not retained and/or stored in the fireproof container. Certified true copies of MPN’s are only allowed to be retained when the original is required to be released to enforce the loan.
Questioned costs: None
Context: Out of a sample of 21 open loans 6 paper signed MPNs were converted to Adobe PDF’s and the original paper MPN was not retained and/or stored in the fireproof container.
Cause: The school was unaware they needed to retain the original copies.
Effect: The school does not have original paper MPNs in a locked, fireproof container.
Repeat Finding: No
Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022-2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); 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. 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 must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award (2 CFR 200.303).
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). We identified the following items of noncompliance:
8 enrollment changes where a student's enrollment status effective date was not correctly reported to NSLDS. (34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2))
1 instance where a student’s enrollment status change was not reported timely to NSLDS. (34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2))
Questioned costs: None
Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 9 instances with exceptions as described above.
Cause: The University was unaware of the errors which were caused by the transmission of date between their student information system and the third-party servicer.
Effect: The NSLDS system could not be updated accurately or timely with student enrollment information.
Repeat Finding: No
Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to
ensure that reporting is completed accurately and timely.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022-2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); 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. 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 must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award (2 CFR 200.303).
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). We identified the following items of noncompliance:
8 enrollment changes where a student's enrollment status effective date was not correctly reported to NSLDS. (34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2))
1 instance where a student’s enrollment status change was not reported timely to NSLDS. (34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2))
Questioned costs: None
Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 9 instances with exceptions as described above.
Cause: The University was unaware of the errors which were caused by the transmission of date between their student information system and the third-party servicer.
Effect: The NSLDS system could not be updated accurately or timely with student enrollment information.
Repeat Finding: No
Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to
ensure that reporting is completed accurately and timely.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022-2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); 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. 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 must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award (2 CFR 200.303).
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). We identified the following items of noncompliance:
8 enrollment changes where a student's enrollment status effective date was not correctly reported to NSLDS. (34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2))
1 instance where a student’s enrollment status change was not reported timely to NSLDS. (34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2))
Questioned costs: None
Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 9 instances with exceptions as described above.
Cause: The University was unaware of the errors which were caused by the transmission of date between their student information system and the third-party servicer.
Effect: The NSLDS system could not be updated accurately or timely with student enrollment information.
Repeat Finding: No
Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to
ensure that reporting is completed accurately and timely.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.268
Federal Award Identification Number and Year: P268K32067, 2022-2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 34 CFR 668.164(l) requires an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution. Additionally, if a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award (2 CFR 200.303).
Condition: During our testing of outstanding SFA checks, we identified three checks outstanding that had not been returned to the U.S. Department of Education within 240 days.
Questioned costs: None
Context: Out of our population of 31 outstanding checks, we noted three had the exception described above.
Cause: The University did not have a process in place when these checks were created in fiscal year 2021; when a process was created, it was not retroactively applied to all outstanding SFA checks to date.
Effect: The University did not return all SFA funds timely to the Department of Education.
Repeat Finding: No
Recommendation: CLA recommends that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue.
Views of responsible officials: The University agrees with the finding. Management has developed a
plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022- 2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 34 CFR 668.164(e)(2)(viii) requires institutions must provide an upto-date URL for their contract with a third-party servicer who assist in providing credit balances to students. This publication is published in a centralized database accessible to the public managed by the U.S. Department of Education. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303).
Condition: During our testing the University could not provide support that an up-to-date third party servicer contract and the related contract data was provided to the U.S. Department of Education. Additionally, the University was not included within the database retained by the U.S. Department of Education.
Questioned costs: None
Context: The University did not meet the compliance requirement to report the contract and contract components to the U.S. Department of Education.
Cause: The University was not aware of the requirement and previous personnel did not retain applicable support, if completed.
Effect: The U.S. Department of Education was not provided required information regarding the contract.
Repeat Finding: No
Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022- 2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 34 CFR 668.164(e)(2)(viii) requires institutions must provide an upto-date URL for their contract with a third-party servicer who assist in providing credit balances to students. This publication is published in a centralized database accessible to the public managed by the U.S. Department of Education. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303).
Condition: During our testing the University could not provide support that an up-to-date third party servicer contract and the related contract data was provided to the U.S. Department of Education. Additionally, the University was not included within the database retained by the U.S. Department of Education.
Questioned costs: None
Context: The University did not meet the compliance requirement to report the contract and contract components to the U.S. Department of Education.
Cause: The University was not aware of the requirement and previous personnel did not retain applicable support, if completed.
Effect: The U.S. Department of Education was not provided required information regarding the contract.
Repeat Finding: No
Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022- 2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 34 CFR 668.164(e)(2)(viii) requires institutions must provide an upto-date URL for their contract with a third-party servicer who assist in providing credit balances to students. This publication is published in a centralized database accessible to the public managed by the U.S. Department of Education. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303).
Condition: During our testing the University could not provide support that an up-to-date third party servicer contract and the related contract data was provided to the U.S. Department of Education. Additionally, the University was not included within the database retained by the U.S. Department of Education.
Questioned costs: None
Context: The University did not meet the compliance requirement to report the contract and contract components to the U.S. Department of Education.
Cause: The University was not aware of the requirement and previous personnel did not retain applicable support, if completed.
Effect: The U.S. Department of Education was not provided required information regarding the contract.
Repeat Finding: No
Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.038
Federal Award Identification Number and Year: N/A – Revolving Loan Portfolio
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 34 CFR 674.19 (e)(4)(i) requires an institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303).
Condition: During our testing of the open Perkins Loans, we selected a sample of 21 loans, 6 of the loans tested were paper MPNs electronically copied to Adobe PDF and the paper MPNs were not retained and/or stored in the fireproof container. Certified true copies of MPN’s are only allowed to be retained when the original is required to be released to enforce the loan.
Questioned costs: None
Context: Out of a sample of 21 open loans 6 paper signed MPNs were converted to Adobe PDF’s and the original paper MPN was not retained and/or stored in the fireproof container.
Cause: The school was unaware they needed to retain the original copies.
Effect: The school does not have original paper MPNs in a locked, fireproof container.
Repeat Finding: No
Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.