Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
Finding 2023-002 – E-Sign Act
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: All
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: 2022-23 Academic Year
Pass-through Entity: Not applicable
Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act)
Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent to participate in electronic transactions was not obtained for 21 of the students, each of which occurred during the 2022-23 academic year.
Questioned Costs: None
Cause: Prior to the 2023-24 academic year, the University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept.
Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation.
Recommendation: Management identified and remediated the process deficiency beginning with the 2023-24 academic year fall semester. We note the four remaining selections of the 25 above were from this semester, and each provided voluntary consent to participate in electronic transactions. However, the University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent.
View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.