Return of Title IV (R2T4) Order of Funds Returned Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: R2T4 funds must be distributed in the order prescribed below. The prescribed order must be followed regardless of the institution?s agreements with other state agencies or private agencies (34 CFR 668.22(i)). a. Unsubsidized Federal Direct Stafford Loans b. Subsidized Federal Direct Stafford Loans c. Federal Direct PLUS d. Federal Pell Grant e. Iraq and Afghanistan Service Grant f. Federal Supplemental Educational Opportunity Grants g. Teacher Education Assistance for College and Higher Education Grants Condition: During our testing, it was noted that the University's process did not ensure that funds that were calculated to return were returned to the Department of Education in the correct order. Questioned costs: None. Context: During our testing of 27 students, 1 student's calculated returned funds were not returned to the Department of Education in the proper order. Cause: The University does not have a review process in place to ensure that the calculated funds to return were returned to the Department of Education in the proper order. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University implements procedures to ensure that Title IV funds that are to be returned are returned in the proper order. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Calculations Scheduled Breaks Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted that the University's process did not ensure scheduled breaks were properly factored in the R2T4 calculations for Spring 2022 term. Questioned costs: $733 known questioned costs. Context: During our tested of 27 students, we noted 1 student's R2T4 calculation where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: ? In our sample of 40 students tested, 2 students were not reported to the NSLDS. ? In our sample of 40 students tested, 2 students were not reported timely within the 30 or 60 day timeframe. ? In our sample of 40 students tested, 2 students did not have the correct enrollment effective date in the NSLDS at the campus and program level. ? In our sample of 40 students tested, 2 students? program descriptions per the University?s records did not match the program description per the program level of the NSLDS. Cause: The University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University?s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat finding: Yes, 2021-002. Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Order of Funds Returned Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: R2T4 funds must be distributed in the order prescribed below. The prescribed order must be followed regardless of the institution?s agreements with other state agencies or private agencies (34 CFR 668.22(i)). a. Unsubsidized Federal Direct Stafford Loans b. Subsidized Federal Direct Stafford Loans c. Federal Direct PLUS d. Federal Pell Grant e. Iraq and Afghanistan Service Grant f. Federal Supplemental Educational Opportunity Grants g. Teacher Education Assistance for College and Higher Education Grants Condition: During our testing, it was noted that the University's process did not ensure that funds that were calculated to return were returned to the Department of Education in the correct order. Questioned costs: None. Context: During our testing of 27 students, 1 student's calculated returned funds were not returned to the Department of Education in the proper order. Cause: The University does not have a review process in place to ensure that the calculated funds to return were returned to the Department of Education in the proper order. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University implements procedures to ensure that Title IV funds that are to be returned are returned in the proper order. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: ? In our sample of 40 students tested, 2 students were not reported to the NSLDS. ? In our sample of 40 students tested, 2 students were not reported timely within the 30 or 60 day timeframe. ? In our sample of 40 students tested, 2 students did not have the correct enrollment effective date in the NSLDS at the campus and program level. ? In our sample of 40 students tested, 2 students? program descriptions per the University?s records did not match the program description per the program level of the NSLDS. Cause: The University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University?s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat finding: Yes, 2021-002. Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Calculations Scheduled Breaks Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted that the University's process did not ensure scheduled breaks were properly factored in the R2T4 calculations for Spring 2022 term. Questioned costs: $733 known questioned costs. Context: During our tested of 27 students, we noted 1 student's R2T4 calculation where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Order of Funds Returned Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: R2T4 funds must be distributed in the order prescribed below. The prescribed order must be followed regardless of the institution?s agreements with other state agencies or private agencies (34 CFR 668.22(i)). a. Unsubsidized Federal Direct Stafford Loans b. Subsidized Federal Direct Stafford Loans c. Federal Direct PLUS d. Federal Pell Grant e. Iraq and Afghanistan Service Grant f. Federal Supplemental Educational Opportunity Grants g. Teacher Education Assistance for College and Higher Education Grants Condition: During our testing, it was noted that the University's process did not ensure that funds that were calculated to return were returned to the Department of Education in the correct order. Questioned costs: None. Context: During our testing of 27 students, 1 student's calculated returned funds were not returned to the Department of Education in the proper order. Cause: The University does not have a review process in place to ensure that the calculated funds to return were returned to the Department of Education in the proper order. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University implements procedures to ensure that Title IV funds that are to be returned are returned in the proper order. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Calculations Scheduled Breaks Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted that the University's process did not ensure scheduled breaks were properly factored in the R2T4 calculations for Spring 2022 term. Questioned costs: $733 known questioned costs. Context: During our tested of 27 students, we noted 1 student's R2T4 calculation where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Perkins Loan Program Record Retention Federal Agency: U.S. Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing Number: 84.038 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, an institution shall retain disbursement and electronic authentication and signature records for each loan made using a Master Promissory Note (MPN) for at least three years from the date the loan is cancelled, repaid, or otherwise satisfied. (34 CFR 674.19 (e)). Condition: Certain loan MPNs were not retained for the three-year retention period. Questioned costs: None. Context: During our testing, we noted 7 of 40 loans tested that the University did not have a MPN on file. Cause: The University does not have a review process in place to ensure the MPNs are kept for least three years from the date the loan is cancelled, repaid, or otherwise satisfied. Effect: The University does not have a proper internal control system for the Federal Perkins Loan Program. Repeat finding: Yes, 2021-001. Recommendation: We recommend that the University keep MPNs for loans for the three-year retention period. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Calculations Scheduled Breaks Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted that the University's process did not ensure scheduled breaks were properly factored in the R2T4 calculations for Spring 2022 term. Questioned costs: $733 known questioned costs. Context: During our tested of 27 students, we noted 1 student's R2T4 calculation where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Order of Funds Returned Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: R2T4 funds must be distributed in the order prescribed below. The prescribed order must be followed regardless of the institution?s agreements with other state agencies or private agencies (34 CFR 668.22(i)). a. Unsubsidized Federal Direct Stafford Loans b. Subsidized Federal Direct Stafford Loans c. Federal Direct PLUS d. Federal Pell Grant e. Iraq and Afghanistan Service Grant f. Federal Supplemental Educational Opportunity Grants g. Teacher Education Assistance for College and Higher Education Grants Condition: During our testing, it was noted that the University's process did not ensure that funds that were calculated to return were returned to the Department of Education in the correct order. Questioned costs: None. Context: During our testing of 27 students, 1 student's calculated returned funds were not returned to the Department of Education in the proper order. Cause: The University does not have a review process in place to ensure that the calculated funds to return were returned to the Department of Education in the proper order. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University implements procedures to ensure that Title IV funds that are to be returned are returned in the proper order. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Higher Education Emergency Relief Fund (HEERF) Student Aid Portion Reporting Federal Agency: U.S. Department of Education Federal Program Name: Higher Education Emergency Relief Fund ? Student Aid Portion Assistance Listing Number: 84.425E Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Reporting Criteria or specific requirement: Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES) directs institutions receiving funds under Section 18004 of CARES to submit (in a time and manner required by the U.S. Department of Education (ED)), a report describing the use of funds distributed from the Higher Education Emergency Relief Fund (HEERF). The ED published additional information that described the public reporting requirements for emergency financial aid grants to students which extended this requirement to funds received under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan (ARP). In addition to posting information within 10 days after the end of each calendar quarter, the following information must appear in a format and location that is easily accessible to the public: 1. An acknowledgement that the institution signed and returned to the Department the Certification and Agreement and the assurance that the institution has used the applicable amount of funds designated under the CARES, CRRSAA and/or ARP (the programs) programs to provide emergency financial aid grants to students. 2. The total amount of funds that the institution will receive or has received from the Department pursuant to the institution?s Certification and Agreement for Emergency Financial Aid Grants to Students under the programs. 3. The total amount of Emergency Financial Aid Grants distributed to students under the programs as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). 4. The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the programs. 5. The total number of students who have received an Emergency Financial Aid Grant to students under the programs. 6. The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under programs. 7. Any instructions, directions, or guidance provided by the institution to students concerning the Emergency Financial Aid Grants. Condition: During our testing of the quarterly public reports for the student aid portion, we noted the University did not post one student quarterly report to their website timely and did not include all required information within the reports. Questioned costs: None. Context: During our testing of the quarterly public reports for the student aid portion, we note: ? In our sample of 2 quarterly public reports tested, 1 report was not published to the University?s website within the required timeframe. ? In our sample of 2 quarterly public reports tested, both reports did not include item number 5 above. ? In our sample of 2 quarterly public reports tested, 1 report (quarter ending December 31, 2021) did not include all the data through the end of the quarter reporting period. Cause: The University did not have procedures in place to ensure reports were being posted to the website on a timely basis or that they included the required information. Effect: Quarterly report was not posted timely to the website and/or did not include the required information resulting in the University being out of compliance with ED reporting guidelines. Repeat finding: No. Recommendation: We recommend the University establish a system to review reports for accuracy as well as ensure timely posting in accordance with applicable reporting requirements. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Order of Funds Returned Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: R2T4 funds must be distributed in the order prescribed below. The prescribed order must be followed regardless of the institution?s agreements with other state agencies or private agencies (34 CFR 668.22(i)). a. Unsubsidized Federal Direct Stafford Loans b. Subsidized Federal Direct Stafford Loans c. Federal Direct PLUS d. Federal Pell Grant e. Iraq and Afghanistan Service Grant f. Federal Supplemental Educational Opportunity Grants g. Teacher Education Assistance for College and Higher Education Grants Condition: During our testing, it was noted that the University's process did not ensure that funds that were calculated to return were returned to the Department of Education in the correct order. Questioned costs: None. Context: During our testing of 27 students, 1 student's calculated returned funds were not returned to the Department of Education in the proper order. Cause: The University does not have a review process in place to ensure that the calculated funds to return were returned to the Department of Education in the proper order. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University implements procedures to ensure that Title IV funds that are to be returned are returned in the proper order. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Calculations Scheduled Breaks Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted that the University's process did not ensure scheduled breaks were properly factored in the R2T4 calculations for Spring 2022 term. Questioned costs: $733 known questioned costs. Context: During our tested of 27 students, we noted 1 student's R2T4 calculation where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: ? In our sample of 40 students tested, 2 students were not reported to the NSLDS. ? In our sample of 40 students tested, 2 students were not reported timely within the 30 or 60 day timeframe. ? In our sample of 40 students tested, 2 students did not have the correct enrollment effective date in the NSLDS at the campus and program level. ? In our sample of 40 students tested, 2 students? program descriptions per the University?s records did not match the program description per the program level of the NSLDS. Cause: The University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University?s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat finding: Yes, 2021-002. Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Order of Funds Returned Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: R2T4 funds must be distributed in the order prescribed below. The prescribed order must be followed regardless of the institution?s agreements with other state agencies or private agencies (34 CFR 668.22(i)). a. Unsubsidized Federal Direct Stafford Loans b. Subsidized Federal Direct Stafford Loans c. Federal Direct PLUS d. Federal Pell Grant e. Iraq and Afghanistan Service Grant f. Federal Supplemental Educational Opportunity Grants g. Teacher Education Assistance for College and Higher Education Grants Condition: During our testing, it was noted that the University's process did not ensure that funds that were calculated to return were returned to the Department of Education in the correct order. Questioned costs: None. Context: During our testing of 27 students, 1 student's calculated returned funds were not returned to the Department of Education in the proper order. Cause: The University does not have a review process in place to ensure that the calculated funds to return were returned to the Department of Education in the proper order. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University implements procedures to ensure that Title IV funds that are to be returned are returned in the proper order. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: ? In our sample of 40 students tested, 2 students were not reported to the NSLDS. ? In our sample of 40 students tested, 2 students were not reported timely within the 30 or 60 day timeframe. ? In our sample of 40 students tested, 2 students did not have the correct enrollment effective date in the NSLDS at the campus and program level. ? In our sample of 40 students tested, 2 students? program descriptions per the University?s records did not match the program description per the program level of the NSLDS. Cause: The University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University?s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat finding: Yes, 2021-002. Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Calculations Scheduled Breaks Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted that the University's process did not ensure scheduled breaks were properly factored in the R2T4 calculations for Spring 2022 term. Questioned costs: $733 known questioned costs. Context: During our tested of 27 students, we noted 1 student's R2T4 calculation where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Order of Funds Returned Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: R2T4 funds must be distributed in the order prescribed below. The prescribed order must be followed regardless of the institution?s agreements with other state agencies or private agencies (34 CFR 668.22(i)). a. Unsubsidized Federal Direct Stafford Loans b. Subsidized Federal Direct Stafford Loans c. Federal Direct PLUS d. Federal Pell Grant e. Iraq and Afghanistan Service Grant f. Federal Supplemental Educational Opportunity Grants g. Teacher Education Assistance for College and Higher Education Grants Condition: During our testing, it was noted that the University's process did not ensure that funds that were calculated to return were returned to the Department of Education in the correct order. Questioned costs: None. Context: During our testing of 27 students, 1 student's calculated returned funds were not returned to the Department of Education in the proper order. Cause: The University does not have a review process in place to ensure that the calculated funds to return were returned to the Department of Education in the proper order. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University implements procedures to ensure that Title IV funds that are to be returned are returned in the proper order. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Calculations Scheduled Breaks Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted that the University's process did not ensure scheduled breaks were properly factored in the R2T4 calculations for Spring 2022 term. Questioned costs: $733 known questioned costs. Context: During our tested of 27 students, we noted 1 student's R2T4 calculation where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Perkins Loan Program Record Retention Federal Agency: U.S. Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing Number: 84.038 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, an institution shall retain disbursement and electronic authentication and signature records for each loan made using a Master Promissory Note (MPN) for at least three years from the date the loan is cancelled, repaid, or otherwise satisfied. (34 CFR 674.19 (e)). Condition: Certain loan MPNs were not retained for the three-year retention period. Questioned costs: None. Context: During our testing, we noted 7 of 40 loans tested that the University did not have a MPN on file. Cause: The University does not have a review process in place to ensure the MPNs are kept for least three years from the date the loan is cancelled, repaid, or otherwise satisfied. Effect: The University does not have a proper internal control system for the Federal Perkins Loan Program. Repeat finding: Yes, 2021-001. Recommendation: We recommend that the University keep MPNs for loans for the three-year retention period. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Calculations Scheduled Breaks Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted that the University's process did not ensure scheduled breaks were properly factored in the R2T4 calculations for Spring 2022 term. Questioned costs: $733 known questioned costs. Context: During our tested of 27 students, we noted 1 student's R2T4 calculation where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Return of Title IV (R2T4) Order of Funds Returned Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: R2T4 funds must be distributed in the order prescribed below. The prescribed order must be followed regardless of the institution?s agreements with other state agencies or private agencies (34 CFR 668.22(i)). a. Unsubsidized Federal Direct Stafford Loans b. Subsidized Federal Direct Stafford Loans c. Federal Direct PLUS d. Federal Pell Grant e. Iraq and Afghanistan Service Grant f. Federal Supplemental Educational Opportunity Grants g. Teacher Education Assistance for College and Higher Education Grants Condition: During our testing, it was noted that the University's process did not ensure that funds that were calculated to return were returned to the Department of Education in the correct order. Questioned costs: None. Context: During our testing of 27 students, 1 student's calculated returned funds were not returned to the Department of Education in the proper order. Cause: The University does not have a review process in place to ensure that the calculated funds to return were returned to the Department of Education in the proper order. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University implements procedures to ensure that Title IV funds that are to be returned are returned in the proper order. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Higher Education Emergency Relief Fund (HEERF) Student Aid Portion Reporting Federal Agency: U.S. Department of Education Federal Program Name: Higher Education Emergency Relief Fund ? Student Aid Portion Assistance Listing Number: 84.425E Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Reporting Criteria or specific requirement: Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES) directs institutions receiving funds under Section 18004 of CARES to submit (in a time and manner required by the U.S. Department of Education (ED)), a report describing the use of funds distributed from the Higher Education Emergency Relief Fund (HEERF). The ED published additional information that described the public reporting requirements for emergency financial aid grants to students which extended this requirement to funds received under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan (ARP). In addition to posting information within 10 days after the end of each calendar quarter, the following information must appear in a format and location that is easily accessible to the public: 1. An acknowledgement that the institution signed and returned to the Department the Certification and Agreement and the assurance that the institution has used the applicable amount of funds designated under the CARES, CRRSAA and/or ARP (the programs) programs to provide emergency financial aid grants to students. 2. The total amount of funds that the institution will receive or has received from the Department pursuant to the institution?s Certification and Agreement for Emergency Financial Aid Grants to Students under the programs. 3. The total amount of Emergency Financial Aid Grants distributed to students under the programs as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). 4. The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the programs. 5. The total number of students who have received an Emergency Financial Aid Grant to students under the programs. 6. The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under programs. 7. Any instructions, directions, or guidance provided by the institution to students concerning the Emergency Financial Aid Grants. Condition: During our testing of the quarterly public reports for the student aid portion, we noted the University did not post one student quarterly report to their website timely and did not include all required information within the reports. Questioned costs: None. Context: During our testing of the quarterly public reports for the student aid portion, we note: ? In our sample of 2 quarterly public reports tested, 1 report was not published to the University?s website within the required timeframe. ? In our sample of 2 quarterly public reports tested, both reports did not include item number 5 above. ? In our sample of 2 quarterly public reports tested, 1 report (quarter ending December 31, 2021) did not include all the data through the end of the quarter reporting period. Cause: The University did not have procedures in place to ensure reports were being posted to the website on a timely basis or that they included the required information. Effect: Quarterly report was not posted timely to the website and/or did not include the required information resulting in the University being out of compliance with ED reporting guidelines. Repeat finding: No. Recommendation: We recommend the University establish a system to review reports for accuracy as well as ensure timely posting in accordance with applicable reporting requirements. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.