Reference Number: 2023-001
Compliance Requirement: Special Tests and Provisions
Type of Finding: Compliance and Internal Control
Internal Control Impact: Significant Deficiency
Compliance Impact: None
AL Number(s) and Title(s): Student Financial Assistance Cluster
84.063 Federal Pell Grant Program
84.007 Federal Supplemental Educational Opportunity Program
84.033 Federal Work Study Program
84.268 Federal Direct Student Loans
93.264 Nurse Faculty Loan Program (NFLP)
Federal Awarding Agency: U. S. Department of Education
Federal Award Number: P063P221055
P007A220074
P033A220074
P268K231055
2 E10HP39215-03-00
Pass-through Entity: None
Pass-through Award Number: None
Questioned Costs: None
The University failed to properly determine if a return to Title IV was necessary.
Finding
According to 34 CFR 668.22, when a Title IV grant recipient withdraws from an institution
during a period in which the recipient began attendance, the institution must determine the
amount of Title IV grant or loan assistance earned by the student as of the student’s withdrawal
date. If the total amount of Title IV grant or loan assistance that the student earned is less than
the amount of Title IV grant or loan assistance that was disbursed to the student, the difference
must be returned to the Title IV programs. If the amount of Title IV grant or loan assistance that
the student earned is greater than the amount of Title IV grant or loan assistance that was
disbursed to the student, the amounts must be treated as a post withdrawal disbursement. Title IV
aid is considered 100% earned by the student if 60% of the payment period or period of
enrollment has occurred after the student’s withdrawal date. Guidance indicates that regardless
of when the student withdraws, a return of Title IV funds (R2T4) must be performed if all Title
IV grant or loan assistance was not already disbursed prior to the withdrawal. If all aid was
disbursed the financial aid administrator can just note in the student’s file that no R2T4
calculation is required after the 60 percent point and all aid was disbursed, so there cannot be a
post-withdrawal disbursement.
In order to test R2T4s, a sample of twenty-five students was selected from a population of 154
student records identified as receiving all F's or total withdrawals during the financial aid award
year. The procedures used by the University include performing a R2T4 for students that
officially withdraw up to and after the 60% point. Audit tests revealed the University did not
calculate a R2T4 for one student in a payment period who was a total withdrawal. The student
officially withdrew after the 60% point from four payment periods during the financial aid year,
but the University only performed three R2T4 calculations. Although calculations during the
audit revealed that the student had earned all of the Title IV aid and no post-withdrawal
disbursement was required, the University failed to either perform a R2T4 calculation or note in
the student’s file that no return or post-withdrawal disbursement was needed.
Recommendation
The University should develop and consistently follow procedures used to perform Title IV
refund calculations for students that withdraw after the 60 percent point that comply with
Title 34 of the Code of Federal Regulations, Part 668.22.
Views of Responsible Officials of the Auditee
Management agrees with this finding and will take corrective actions as detailed in the corrective
action plan.
Reference Number: 2023-001
Compliance Requirement: Special Tests and Provisions
Type of Finding: Compliance and Internal Control
Internal Control Impact: Significant Deficiency
Compliance Impact: None
AL Number(s) and Title(s): Student Financial Assistance Cluster
84.063 Federal Pell Grant Program
84.007 Federal Supplemental Educational Opportunity Program
84.033 Federal Work Study Program
84.268 Federal Direct Student Loans
93.264 Nurse Faculty Loan Program (NFLP)
Federal Awarding Agency: U. S. Department of Education
Federal Award Number: P063P221055
P007A220074
P033A220074
P268K231055
2 E10HP39215-03-00
Pass-through Entity: None
Pass-through Award Number: None
Questioned Costs: None
The University failed to properly determine if a return to Title IV was necessary.
Finding
According to 34 CFR 668.22, when a Title IV grant recipient withdraws from an institution
during a period in which the recipient began attendance, the institution must determine the
amount of Title IV grant or loan assistance earned by the student as of the student’s withdrawal
date. If the total amount of Title IV grant or loan assistance that the student earned is less than
the amount of Title IV grant or loan assistance that was disbursed to the student, the difference
must be returned to the Title IV programs. If the amount of Title IV grant or loan assistance that
the student earned is greater than the amount of Title IV grant or loan assistance that was
disbursed to the student, the amounts must be treated as a post withdrawal disbursement. Title IV
aid is considered 100% earned by the student if 60% of the payment period or period of
enrollment has occurred after the student’s withdrawal date. Guidance indicates that regardless
of when the student withdraws, a return of Title IV funds (R2T4) must be performed if all Title
IV grant or loan assistance was not already disbursed prior to the withdrawal. If all aid was
disbursed the financial aid administrator can just note in the student’s file that no R2T4
calculation is required after the 60 percent point and all aid was disbursed, so there cannot be a
post-withdrawal disbursement.
In order to test R2T4s, a sample of twenty-five students was selected from a population of 154
student records identified as receiving all F's or total withdrawals during the financial aid award
year. The procedures used by the University include performing a R2T4 for students that
officially withdraw up to and after the 60% point. Audit tests revealed the University did not
calculate a R2T4 for one student in a payment period who was a total withdrawal. The student
officially withdrew after the 60% point from four payment periods during the financial aid year,
but the University only performed three R2T4 calculations. Although calculations during the
audit revealed that the student had earned all of the Title IV aid and no post-withdrawal
disbursement was required, the University failed to either perform a R2T4 calculation or note in
the student’s file that no return or post-withdrawal disbursement was needed.
Recommendation
The University should develop and consistently follow procedures used to perform Title IV
refund calculations for students that withdraw after the 60 percent point that comply with
Title 34 of the Code of Federal Regulations, Part 668.22.
Views of Responsible Officials of the Auditee
Management agrees with this finding and will take corrective actions as detailed in the corrective
action plan.
Reference Number: 2023-002
Compliance Requirement: Eligibility
Type of Finding: Compliance and Internal Control
Internal Control Impact: Material Weakness
Compliance Impact: Nonmaterial Noncompliance
AL Number(s) and Title(s): Student Financial Assistance Cluster
84.063 Federal Pell Grant Program
84.007 Federal Supplemental Educational Opportunity Program
84.033 Federal Work Study Program
84.268 Federal Direct Student Loans
93.264 Nurse Faculty Loan Program (NFLP)
Federal Awarding Agency: U. S. Department of Education
Federal Award Number: P063P221055
P007A220074
P033A220074
P268K231055
2 E10HP39215-03-00
Pass-through Entity: None
Pass-through Award Number: None
Questioned Costs: $14,609.00
The University failed to verify whether students began attendance in classes prior to
disbursing Title IV aid.
Finding
Title 34 of the Code of Federal Regulations (CFR) Part 690.80 requires the recalculation of a
Federal Pell Grant award to account for changes to the student’s costs, expected family
contribution (EFC), or enrollment status. For a change in the student’s enrollment status from
one academic term to another term within the same award year, the institution shall recalculate
the Federal Pell Grant award for the new payment period. If a student’s projected enrollment
status changes during a payment period before the student begins attendance in all of his or her
classes for that payment period, the institution shall recalculate the student’s enrollment status to
reflect only those classes for which the student actually began attendance.
Schedule of Findings and Questioned Costs
For the Year Ended September 30, 2023
Twenty-five students were selected for return to Title IV testing from a population of student
records identified by the University as students receiving all F’s or total withdrawals for the
financial aid award year. Although these students did not require a return to Title IV, it was
noted during this test that four students had not begun attendance in all classes or never attended
any classes for the term enrolled. Further testing revealed the University failed to properly verify
attendance for these students and recalculate the federal financial assistance based on the
enrollment or change in enrollment status, as required. Failure to review changes in enrollment
status and recalculate awards as required could result in overawards to noneligible recipients and
noncompliance in the Title IV programs. These students were awarded $8,313 in Pell and
$6,296 in Direct Loans which resulted in overawards of these amounts.
Recommendation
The University should verify whether students begin attendance in registered classes and
recalculate Federal Pell Grant and Federal Direct Student Loan awards based on enrollment or
change in enrollment status, in accordance with Title 34 of the Code of Federal Regulations,
Part 690.80.
Views of Responsible Officials of the Auditee
Management agrees with this finding and will take corrective actions as detailed in the corrective
action plan.
Reference Number: 2023-002
Compliance Requirement: Eligibility
Type of Finding: Compliance and Internal Control
Internal Control Impact: Material Weakness
Compliance Impact: Nonmaterial Noncompliance
AL Number(s) and Title(s): Student Financial Assistance Cluster
84.063 Federal Pell Grant Program
84.007 Federal Supplemental Educational Opportunity Program
84.033 Federal Work Study Program
84.268 Federal Direct Student Loans
93.264 Nurse Faculty Loan Program (NFLP)
Federal Awarding Agency: U. S. Department of Education
Federal Award Number: P063P221055
P007A220074
P033A220074
P268K231055
2 E10HP39215-03-00
Pass-through Entity: None
Pass-through Award Number: None
Questioned Costs: $14,609.00
The University failed to verify whether students began attendance in classes prior to
disbursing Title IV aid.
Finding
Title 34 of the Code of Federal Regulations (CFR) Part 690.80 requires the recalculation of a
Federal Pell Grant award to account for changes to the student’s costs, expected family
contribution (EFC), or enrollment status. For a change in the student’s enrollment status from
one academic term to another term within the same award year, the institution shall recalculate
the Federal Pell Grant award for the new payment period. If a student’s projected enrollment
status changes during a payment period before the student begins attendance in all of his or her
classes for that payment period, the institution shall recalculate the student’s enrollment status to
reflect only those classes for which the student actually began attendance.
Schedule of Findings and Questioned Costs
For the Year Ended September 30, 2023
Twenty-five students were selected for return to Title IV testing from a population of student
records identified by the University as students receiving all F’s or total withdrawals for the
financial aid award year. Although these students did not require a return to Title IV, it was
noted during this test that four students had not begun attendance in all classes or never attended
any classes for the term enrolled. Further testing revealed the University failed to properly verify
attendance for these students and recalculate the federal financial assistance based on the
enrollment or change in enrollment status, as required. Failure to review changes in enrollment
status and recalculate awards as required could result in overawards to noneligible recipients and
noncompliance in the Title IV programs. These students were awarded $8,313 in Pell and
$6,296 in Direct Loans which resulted in overawards of these amounts.
Recommendation
The University should verify whether students begin attendance in registered classes and
recalculate Federal Pell Grant and Federal Direct Student Loan awards based on enrollment or
change in enrollment status, in accordance with Title 34 of the Code of Federal Regulations,
Part 690.80.
Views of Responsible Officials of the Auditee
Management agrees with this finding and will take corrective actions as detailed in the corrective
action plan.
Reference Number: 2023-001
Compliance Requirement: Special Tests and Provisions
Type of Finding: Compliance and Internal Control
Internal Control Impact: Significant Deficiency
Compliance Impact: None
AL Number(s) and Title(s): Student Financial Assistance Cluster
84.063 Federal Pell Grant Program
84.007 Federal Supplemental Educational Opportunity Program
84.033 Federal Work Study Program
84.268 Federal Direct Student Loans
93.264 Nurse Faculty Loan Program (NFLP)
Federal Awarding Agency: U. S. Department of Education
Federal Award Number: P063P221055
P007A220074
P033A220074
P268K231055
2 E10HP39215-03-00
Pass-through Entity: None
Pass-through Award Number: None
Questioned Costs: None
The University failed to properly determine if a return to Title IV was necessary.
Finding
According to 34 CFR 668.22, when a Title IV grant recipient withdraws from an institution
during a period in which the recipient began attendance, the institution must determine the
amount of Title IV grant or loan assistance earned by the student as of the student’s withdrawal
date. If the total amount of Title IV grant or loan assistance that the student earned is less than
the amount of Title IV grant or loan assistance that was disbursed to the student, the difference
must be returned to the Title IV programs. If the amount of Title IV grant or loan assistance that
the student earned is greater than the amount of Title IV grant or loan assistance that was
disbursed to the student, the amounts must be treated as a post withdrawal disbursement. Title IV
aid is considered 100% earned by the student if 60% of the payment period or period of
enrollment has occurred after the student’s withdrawal date. Guidance indicates that regardless
of when the student withdraws, a return of Title IV funds (R2T4) must be performed if all Title
IV grant or loan assistance was not already disbursed prior to the withdrawal. If all aid was
disbursed the financial aid administrator can just note in the student’s file that no R2T4
calculation is required after the 60 percent point and all aid was disbursed, so there cannot be a
post-withdrawal disbursement.
In order to test R2T4s, a sample of twenty-five students was selected from a population of 154
student records identified as receiving all F's or total withdrawals during the financial aid award
year. The procedures used by the University include performing a R2T4 for students that
officially withdraw up to and after the 60% point. Audit tests revealed the University did not
calculate a R2T4 for one student in a payment period who was a total withdrawal. The student
officially withdrew after the 60% point from four payment periods during the financial aid year,
but the University only performed three R2T4 calculations. Although calculations during the
audit revealed that the student had earned all of the Title IV aid and no post-withdrawal
disbursement was required, the University failed to either perform a R2T4 calculation or note in
the student’s file that no return or post-withdrawal disbursement was needed.
Recommendation
The University should develop and consistently follow procedures used to perform Title IV
refund calculations for students that withdraw after the 60 percent point that comply with
Title 34 of the Code of Federal Regulations, Part 668.22.
Views of Responsible Officials of the Auditee
Management agrees with this finding and will take corrective actions as detailed in the corrective
action plan.
Reference Number: 2023-001
Compliance Requirement: Special Tests and Provisions
Type of Finding: Compliance and Internal Control
Internal Control Impact: Significant Deficiency
Compliance Impact: None
AL Number(s) and Title(s): Student Financial Assistance Cluster
84.063 Federal Pell Grant Program
84.007 Federal Supplemental Educational Opportunity Program
84.033 Federal Work Study Program
84.268 Federal Direct Student Loans
93.264 Nurse Faculty Loan Program (NFLP)
Federal Awarding Agency: U. S. Department of Education
Federal Award Number: P063P221055
P007A220074
P033A220074
P268K231055
2 E10HP39215-03-00
Pass-through Entity: None
Pass-through Award Number: None
Questioned Costs: None
The University failed to properly determine if a return to Title IV was necessary.
Finding
According to 34 CFR 668.22, when a Title IV grant recipient withdraws from an institution
during a period in which the recipient began attendance, the institution must determine the
amount of Title IV grant or loan assistance earned by the student as of the student’s withdrawal
date. If the total amount of Title IV grant or loan assistance that the student earned is less than
the amount of Title IV grant or loan assistance that was disbursed to the student, the difference
must be returned to the Title IV programs. If the amount of Title IV grant or loan assistance that
the student earned is greater than the amount of Title IV grant or loan assistance that was
disbursed to the student, the amounts must be treated as a post withdrawal disbursement. Title IV
aid is considered 100% earned by the student if 60% of the payment period or period of
enrollment has occurred after the student’s withdrawal date. Guidance indicates that regardless
of when the student withdraws, a return of Title IV funds (R2T4) must be performed if all Title
IV grant or loan assistance was not already disbursed prior to the withdrawal. If all aid was
disbursed the financial aid administrator can just note in the student’s file that no R2T4
calculation is required after the 60 percent point and all aid was disbursed, so there cannot be a
post-withdrawal disbursement.
In order to test R2T4s, a sample of twenty-five students was selected from a population of 154
student records identified as receiving all F's or total withdrawals during the financial aid award
year. The procedures used by the University include performing a R2T4 for students that
officially withdraw up to and after the 60% point. Audit tests revealed the University did not
calculate a R2T4 for one student in a payment period who was a total withdrawal. The student
officially withdrew after the 60% point from four payment periods during the financial aid year,
but the University only performed three R2T4 calculations. Although calculations during the
audit revealed that the student had earned all of the Title IV aid and no post-withdrawal
disbursement was required, the University failed to either perform a R2T4 calculation or note in
the student’s file that no return or post-withdrawal disbursement was needed.
Recommendation
The University should develop and consistently follow procedures used to perform Title IV
refund calculations for students that withdraw after the 60 percent point that comply with
Title 34 of the Code of Federal Regulations, Part 668.22.
Views of Responsible Officials of the Auditee
Management agrees with this finding and will take corrective actions as detailed in the corrective
action plan.
Reference Number: 2023-002
Compliance Requirement: Eligibility
Type of Finding: Compliance and Internal Control
Internal Control Impact: Material Weakness
Compliance Impact: Nonmaterial Noncompliance
AL Number(s) and Title(s): Student Financial Assistance Cluster
84.063 Federal Pell Grant Program
84.007 Federal Supplemental Educational Opportunity Program
84.033 Federal Work Study Program
84.268 Federal Direct Student Loans
93.264 Nurse Faculty Loan Program (NFLP)
Federal Awarding Agency: U. S. Department of Education
Federal Award Number: P063P221055
P007A220074
P033A220074
P268K231055
2 E10HP39215-03-00
Pass-through Entity: None
Pass-through Award Number: None
Questioned Costs: $14,609.00
The University failed to verify whether students began attendance in classes prior to
disbursing Title IV aid.
Finding
Title 34 of the Code of Federal Regulations (CFR) Part 690.80 requires the recalculation of a
Federal Pell Grant award to account for changes to the student’s costs, expected family
contribution (EFC), or enrollment status. For a change in the student’s enrollment status from
one academic term to another term within the same award year, the institution shall recalculate
the Federal Pell Grant award for the new payment period. If a student’s projected enrollment
status changes during a payment period before the student begins attendance in all of his or her
classes for that payment period, the institution shall recalculate the student’s enrollment status to
reflect only those classes for which the student actually began attendance.
Schedule of Findings and Questioned Costs
For the Year Ended September 30, 2023
Twenty-five students were selected for return to Title IV testing from a population of student
records identified by the University as students receiving all F’s or total withdrawals for the
financial aid award year. Although these students did not require a return to Title IV, it was
noted during this test that four students had not begun attendance in all classes or never attended
any classes for the term enrolled. Further testing revealed the University failed to properly verify
attendance for these students and recalculate the federal financial assistance based on the
enrollment or change in enrollment status, as required. Failure to review changes in enrollment
status and recalculate awards as required could result in overawards to noneligible recipients and
noncompliance in the Title IV programs. These students were awarded $8,313 in Pell and
$6,296 in Direct Loans which resulted in overawards of these amounts.
Recommendation
The University should verify whether students begin attendance in registered classes and
recalculate Federal Pell Grant and Federal Direct Student Loan awards based on enrollment or
change in enrollment status, in accordance with Title 34 of the Code of Federal Regulations,
Part 690.80.
Views of Responsible Officials of the Auditee
Management agrees with this finding and will take corrective actions as detailed in the corrective
action plan.
Reference Number: 2023-002
Compliance Requirement: Eligibility
Type of Finding: Compliance and Internal Control
Internal Control Impact: Material Weakness
Compliance Impact: Nonmaterial Noncompliance
AL Number(s) and Title(s): Student Financial Assistance Cluster
84.063 Federal Pell Grant Program
84.007 Federal Supplemental Educational Opportunity Program
84.033 Federal Work Study Program
84.268 Federal Direct Student Loans
93.264 Nurse Faculty Loan Program (NFLP)
Federal Awarding Agency: U. S. Department of Education
Federal Award Number: P063P221055
P007A220074
P033A220074
P268K231055
2 E10HP39215-03-00
Pass-through Entity: None
Pass-through Award Number: None
Questioned Costs: $14,609.00
The University failed to verify whether students began attendance in classes prior to
disbursing Title IV aid.
Finding
Title 34 of the Code of Federal Regulations (CFR) Part 690.80 requires the recalculation of a
Federal Pell Grant award to account for changes to the student’s costs, expected family
contribution (EFC), or enrollment status. For a change in the student’s enrollment status from
one academic term to another term within the same award year, the institution shall recalculate
the Federal Pell Grant award for the new payment period. If a student’s projected enrollment
status changes during a payment period before the student begins attendance in all of his or her
classes for that payment period, the institution shall recalculate the student’s enrollment status to
reflect only those classes for which the student actually began attendance.
Schedule of Findings and Questioned Costs
For the Year Ended September 30, 2023
Twenty-five students were selected for return to Title IV testing from a population of student
records identified by the University as students receiving all F’s or total withdrawals for the
financial aid award year. Although these students did not require a return to Title IV, it was
noted during this test that four students had not begun attendance in all classes or never attended
any classes for the term enrolled. Further testing revealed the University failed to properly verify
attendance for these students and recalculate the federal financial assistance based on the
enrollment or change in enrollment status, as required. Failure to review changes in enrollment
status and recalculate awards as required could result in overawards to noneligible recipients and
noncompliance in the Title IV programs. These students were awarded $8,313 in Pell and
$6,296 in Direct Loans which resulted in overawards of these amounts.
Recommendation
The University should verify whether students begin attendance in registered classes and
recalculate Federal Pell Grant and Federal Direct Student Loan awards based on enrollment or
change in enrollment status, in accordance with Title 34 of the Code of Federal Regulations,
Part 690.80.
Views of Responsible Officials of the Auditee
Management agrees with this finding and will take corrective actions as detailed in the corrective
action plan.