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: Fiscal year 2023
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 for electronic disbursement participation was not obtained for any of these students.
Questioned Costs: None
Cause: 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: We recommend that management review the requirements of the E-Sign Act with
respect to student electronic transaction voluntary consents and put in place processes that will ensure
such consent is captured in future transactions. The University should continually assess the operation
of the updated policies and procedures in place as it relates to voluntary consent.
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: Fiscal year 2023
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 for electronic disbursement participation was not obtained for any of these students.
Questioned Costs: None
Cause: 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: We recommend that management review the requirements of the E-Sign Act with
respect to student electronic transaction voluntary consents and put in place processes that will ensure
such consent is captured in future transactions. The University should continually assess the operation
of the updated policies and procedures in place as it relates to voluntary consent.
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: Fiscal year 2023
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 for electronic disbursement participation was not obtained for any of these students.
Questioned Costs: None
Cause: 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: We recommend that management review the requirements of the E-Sign Act with
respect to student electronic transaction voluntary consents and put in place processes that will ensure
such consent is captured in future transactions. The University should continually assess the operation
of the updated policies and procedures in place as it relates to voluntary consent.
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: Fiscal year 2023
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 for electronic disbursement participation was not obtained for any of these students.
Questioned Costs: None
Cause: 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: We recommend that management review the requirements of the E-Sign Act with
respect to student electronic transaction voluntary consents and put in place processes that will ensure
such consent is captured in future transactions. The University should continually assess the operation
of the updated policies and procedures in place as it relates to voluntary consent.
Timeliness of Enrollment Reporting
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: 84.038 - Federal Direct Loan Program,
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: Fiscal year 2023
Pass-through Entity: Not applicable
Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, schools are required to report the
enrollment status of students who received Federal Pell Grants and/or Federal Direct Loans to the
National Student Loan Data System (“NSLDS”). Enrollment information, inclusive of campus level and
program level data, must be reviewed, updated, and validated by the institution in a timely manner as it
is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy and grace
period. Specific to the Federal Direct Loan program, enrollment changes, such as a change from full-time
to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to
be reported within 60 days of the change.
Condition: We reviewed a sample of 25 students enrolled at the University who received either Federal
Pell Grants and/or Federal Direct Loans and had a change in enrollment between March 1, 2023 and
September 30, 2023 of the fiscal year. Through our enrollment reporting testing, we identified one
student in which the status change was reported 274 days after the effective date of the change in
enrollment status, which is greater than the 60-day requirement.
Questioned Costs: None
Cause: Although the University has processes and controls to timely report student enrollment changes
to the National Student Clearinghouse (“NSC”) and to the NSLDS, these controls did not operate as
designed during the period to meet the 60-day reporting requirement. The University did not timely
review the unapplied records reported by NSC for the University’s review so that records could be
reported to NSLDS.
Effect: The effective administration of Federal Direct Loans could be impacted when changes in
students’ enrollment are not reported accurately and/or timely. The timeliness of reporting enrollment
information is important, as a student’s enrollment status determines eligibility for in-school status,
deferment, grace period and repayments, as well as the government’s payment of interest subsidies.
Recommendation: We recommend the University enhance its controls and revise its procedures to
ensure that status changes are reported timely to the NSLDS.
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: Fiscal year 2023
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 for electronic disbursement participation was not obtained for any of these students.
Questioned Costs: None
Cause: 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: We recommend that management review the requirements of the E-Sign Act with
respect to student electronic transaction voluntary consents and put in place processes that will ensure
such consent is captured in future transactions. The University should continually assess the operation
of the updated policies and procedures in place as it relates to voluntary consent.
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: Fiscal year 2023
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 for electronic disbursement participation was not obtained for any of these students.
Questioned Costs: None
Cause: 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: We recommend that management review the requirements of the E-Sign Act with
respect to student electronic transaction voluntary consents and put in place processes that will ensure
such consent is captured in future transactions. The University should continually assess the operation
of the updated policies and procedures in place as it relates to voluntary consent.
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: Fiscal year 2023
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 for electronic disbursement participation was not obtained for any of these students.
Questioned Costs: None
Cause: 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: We recommend that management review the requirements of the E-Sign Act with
respect to student electronic transaction voluntary consents and put in place processes that will ensure
such consent is captured in future transactions. The University should continually assess the operation
of the updated policies and procedures in place as it relates to voluntary consent.
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: Fiscal year 2023
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 for electronic disbursement participation was not obtained for any of these students.
Questioned Costs: None
Cause: 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: We recommend that management review the requirements of the E-Sign Act with
respect to student electronic transaction voluntary consents and put in place processes that will ensure
such consent is captured in future transactions. The University should continually assess the operation
of the updated policies and procedures in place as it relates to voluntary consent.
Timeliness of Enrollment Reporting
Cluster: Student Financial Assistance
Federal Agency: Department of Education
Assistance Listing Title and Number: 84.038 - Federal Direct Loan Program,
Award Name: Not applicable
Award Identifying Number: Not applicable
Award Year: Fiscal year 2023
Pass-through Entity: Not applicable
Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, schools are required to report the
enrollment status of students who received Federal Pell Grants and/or Federal Direct Loans to the
National Student Loan Data System (“NSLDS”). Enrollment information, inclusive of campus level and
program level data, must be reviewed, updated, and validated by the institution in a timely manner as it
is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy and grace
period. Specific to the Federal Direct Loan program, enrollment changes, such as a change from full-time
to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to
be reported within 60 days of the change.
Condition: We reviewed a sample of 25 students enrolled at the University who received either Federal
Pell Grants and/or Federal Direct Loans and had a change in enrollment between March 1, 2023 and
September 30, 2023 of the fiscal year. Through our enrollment reporting testing, we identified one
student in which the status change was reported 274 days after the effective date of the change in
enrollment status, which is greater than the 60-day requirement.
Questioned Costs: None
Cause: Although the University has processes and controls to timely report student enrollment changes
to the National Student Clearinghouse (“NSC”) and to the NSLDS, these controls did not operate as
designed during the period to meet the 60-day reporting requirement. The University did not timely
review the unapplied records reported by NSC for the University’s review so that records could be
reported to NSLDS.
Effect: The effective administration of Federal Direct Loans could be impacted when changes in
students’ enrollment are not reported accurately and/or timely. The timeliness of reporting enrollment
information is important, as a student’s enrollment status determines eligibility for in-school status,
deferment, grace period and repayments, as well as the government’s payment of interest subsidies.
Recommendation: We recommend the University enhance its controls and revise its procedures to
ensure that status changes are reported timely to the NSLDS.