2022-002 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew (34 CFR 668.22(e)). Condition: One instance was identified where the Return of Title IV calculation was not completed. Another instance was identified where the Return of Title IV calculation was completed using the incorrect withdrawal date. Additionally, one instance was identified where the Return of Title IV calculation was completed, but the funds were returned late. Cause: The University did not perform a Return of Title IV calculation for students who completed an interim course and then withdrew during the spring semester. The incorrect withdrawal date was used to calculate the amount of aid to be returned. Process to ensure that funds were submitted in a timely manner were not followed. Effect: The University should return an additional $6,506 based on the corrected Return of Title IV calculations. Questioned Costs: None reported over $25,000 Context/Sampling: Of the 30 students in which a Return of Title IV funds were calculated, 11 were tested. There were also 14 additional students that were tested based on a population of all withdrawn students or 78 students. The amount tested was $25,000 of the total population of funds received of $416,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations to ensure that errors are detected and corrected timely. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-003 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2020/2021 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2020/2021 P063P201430 Reporting? Common Origination and Disbursement System Material Weakness in Internal Control over Compliance and Noncompliance Criteria: An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV, HEA program funds are disbursed on the date that the institution: (a) credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition: Three instances were noted where Title IV funds were applied to the student account but were not processed in COD within the required timeframe. Another two instances were noted where Title IV funds were applied to the student account but were not processed in COD at all. Cause: There was no process in place to monitor and correct denials from the COD system in a timely manner. Effect: COD data was not reflective of the date the aid was applied to the student account. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Five instances were identified in 60 students tested. 290 students received Pell disbursements and 669 students received direct loan disbursements. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure loans applied to student accounts are processed in COD within required time frame and monitor and address denials in a timely manner. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-004 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2021/2022 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control Criteria: A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution?s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student?s last date of attendance for withdrawals. Condition: Two instances were noted where enrollment effective date reported to the National Student Clearing House as first effective was not the same as the student?s last date of attendance. Cause: The University did not submit the correct last date of attendance to the National Student Clearing House. Effect: Status The enrollment effective date reported to the National Student Clearing House was not reflective of the student?s last date of attendance. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Two instances were identified in 60 students tested. 450 students had status changes during the year. Repeat Finding from Prior Years: No Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-002 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew (34 CFR 668.22(e)). Condition: One instance was identified where the Return of Title IV calculation was not completed. Another instance was identified where the Return of Title IV calculation was completed using the incorrect withdrawal date. Additionally, one instance was identified where the Return of Title IV calculation was completed, but the funds were returned late. Cause: The University did not perform a Return of Title IV calculation for students who completed an interim course and then withdrew during the spring semester. The incorrect withdrawal date was used to calculate the amount of aid to be returned. Process to ensure that funds were submitted in a timely manner were not followed. Effect: The University should return an additional $6,506 based on the corrected Return of Title IV calculations. Questioned Costs: None reported over $25,000 Context/Sampling: Of the 30 students in which a Return of Title IV funds were calculated, 11 were tested. There were also 14 additional students that were tested based on a population of all withdrawn students or 78 students. The amount tested was $25,000 of the total population of funds received of $416,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations to ensure that errors are detected and corrected timely. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-003 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2020/2021 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2020/2021 P063P201430 Reporting? Common Origination and Disbursement System Material Weakness in Internal Control over Compliance and Noncompliance Criteria: An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV, HEA program funds are disbursed on the date that the institution: (a) credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition: Three instances were noted where Title IV funds were applied to the student account but were not processed in COD within the required timeframe. Another two instances were noted where Title IV funds were applied to the student account but were not processed in COD at all. Cause: There was no process in place to monitor and correct denials from the COD system in a timely manner. Effect: COD data was not reflective of the date the aid was applied to the student account. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Five instances were identified in 60 students tested. 290 students received Pell disbursements and 669 students received direct loan disbursements. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure loans applied to student accounts are processed in COD within required time frame and monitor and address denials in a timely manner. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-004 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2021/2022 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control Criteria: A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution?s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student?s last date of attendance for withdrawals. Condition: Two instances were noted where enrollment effective date reported to the National Student Clearing House as first effective was not the same as the student?s last date of attendance. Cause: The University did not submit the correct last date of attendance to the National Student Clearing House. Effect: Status The enrollment effective date reported to the National Student Clearing House was not reflective of the student?s last date of attendance. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Two instances were identified in 60 students tested. 450 students had status changes during the year. Repeat Finding from Prior Years: No Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-001 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.038 Federal Perkins Loan Program Reporting Material Weakness in Internal Control over Compliance Criteria: 34 CFR 673.3 requires institutions complete the Fiscal Operations Report and Application to Participate (FISAP) to participate in the Federal Perkins Loan Program. The Fiscal Operations Report includes the University?s financial information from the previous award year. Condition: Certain amounts within the FISAP filed during fiscal year 2021 FISAP were reported incorrectly in Part III, Section C, Line 1.1 column (c). Cause: There was a clerical error when typing the number. Effect: Information reported on the FISAP was incorrect. Questioned Costs: None Context/Sampling: Key line items within the FISAP report were tested as required by the OMB Compliance Supplement. No statistical sampling was performed. Repeat Finding from Prior Years: Yes Recommendation: The University should review current processes to ensure that line items reported are accurate. The FISAP review process should include a detail review by an individual independent from the preparer to verify the numbers reported. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-003 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2020/2021 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2020/2021 P063P201430 Reporting? Common Origination and Disbursement System Material Weakness in Internal Control over Compliance and Noncompliance Criteria: An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV, HEA program funds are disbursed on the date that the institution: (a) credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition: Three instances were noted where Title IV funds were applied to the student account but were not processed in COD within the required timeframe. Another two instances were noted where Title IV funds were applied to the student account but were not processed in COD at all. Cause: There was no process in place to monitor and correct denials from the COD system in a timely manner. Effect: COD data was not reflective of the date the aid was applied to the student account. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Five instances were identified in 60 students tested. 290 students received Pell disbursements and 669 students received direct loan disbursements. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure loans applied to student accounts are processed in COD within required time frame and monitor and address denials in a timely manner. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-004 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2021/2022 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control Criteria: A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution?s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student?s last date of attendance for withdrawals. Condition: Two instances were noted where enrollment effective date reported to the National Student Clearing House as first effective was not the same as the student?s last date of attendance. Cause: The University did not submit the correct last date of attendance to the National Student Clearing House. Effect: Status The enrollment effective date reported to the National Student Clearing House was not reflective of the student?s last date of attendance. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Two instances were identified in 60 students tested. 450 students had status changes during the year. Repeat Finding from Prior Years: No Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-002 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew (34 CFR 668.22(e)). Condition: One instance was identified where the Return of Title IV calculation was not completed. Another instance was identified where the Return of Title IV calculation was completed using the incorrect withdrawal date. Additionally, one instance was identified where the Return of Title IV calculation was completed, but the funds were returned late. Cause: The University did not perform a Return of Title IV calculation for students who completed an interim course and then withdrew during the spring semester. The incorrect withdrawal date was used to calculate the amount of aid to be returned. Process to ensure that funds were submitted in a timely manner were not followed. Effect: The University should return an additional $6,506 based on the corrected Return of Title IV calculations. Questioned Costs: None reported over $25,000 Context/Sampling: Of the 30 students in which a Return of Title IV funds were calculated, 11 were tested. There were also 14 additional students that were tested based on a population of all withdrawn students or 78 students. The amount tested was $25,000 of the total population of funds received of $416,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations to ensure that errors are detected and corrected timely. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-003 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2020/2021 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2020/2021 P063P201430 Reporting? Common Origination and Disbursement System Material Weakness in Internal Control over Compliance and Noncompliance Criteria: An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV, HEA program funds are disbursed on the date that the institution: (a) credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition: Three instances were noted where Title IV funds were applied to the student account but were not processed in COD within the required timeframe. Another two instances were noted where Title IV funds were applied to the student account but were not processed in COD at all. Cause: There was no process in place to monitor and correct denials from the COD system in a timely manner. Effect: COD data was not reflective of the date the aid was applied to the student account. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Five instances were identified in 60 students tested. 290 students received Pell disbursements and 669 students received direct loan disbursements. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure loans applied to student accounts are processed in COD within required time frame and monitor and address denials in a timely manner. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-004 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2021/2022 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control Criteria: A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution?s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student?s last date of attendance for withdrawals. Condition: Two instances were noted where enrollment effective date reported to the National Student Clearing House as first effective was not the same as the student?s last date of attendance. Cause: The University did not submit the correct last date of attendance to the National Student Clearing House. Effect: Status The enrollment effective date reported to the National Student Clearing House was not reflective of the student?s last date of attendance. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Two instances were identified in 60 students tested. 450 students had status changes during the year. Repeat Finding from Prior Years: No Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-002 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew (34 CFR 668.22(e)). Condition: One instance was identified where the Return of Title IV calculation was not completed. Another instance was identified where the Return of Title IV calculation was completed using the incorrect withdrawal date. Additionally, one instance was identified where the Return of Title IV calculation was completed, but the funds were returned late. Cause: The University did not perform a Return of Title IV calculation for students who completed an interim course and then withdrew during the spring semester. The incorrect withdrawal date was used to calculate the amount of aid to be returned. Process to ensure that funds were submitted in a timely manner were not followed. Effect: The University should return an additional $6,506 based on the corrected Return of Title IV calculations. Questioned Costs: None reported over $25,000 Context/Sampling: Of the 30 students in which a Return of Title IV funds were calculated, 11 were tested. There were also 14 additional students that were tested based on a population of all withdrawn students or 78 students. The amount tested was $25,000 of the total population of funds received of $416,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations to ensure that errors are detected and corrected timely. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-003 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2020/2021 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2020/2021 P063P201430 Reporting? Common Origination and Disbursement System Material Weakness in Internal Control over Compliance and Noncompliance Criteria: An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV, HEA program funds are disbursed on the date that the institution: (a) credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition: Three instances were noted where Title IV funds were applied to the student account but were not processed in COD within the required timeframe. Another two instances were noted where Title IV funds were applied to the student account but were not processed in COD at all. Cause: There was no process in place to monitor and correct denials from the COD system in a timely manner. Effect: COD data was not reflective of the date the aid was applied to the student account. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Five instances were identified in 60 students tested. 290 students received Pell disbursements and 669 students received direct loan disbursements. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure loans applied to student accounts are processed in COD within required time frame and monitor and address denials in a timely manner. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-004 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2021/2022 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control Criteria: A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution?s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student?s last date of attendance for withdrawals. Condition: Two instances were noted where enrollment effective date reported to the National Student Clearing House as first effective was not the same as the student?s last date of attendance. Cause: The University did not submit the correct last date of attendance to the National Student Clearing House. Effect: Status The enrollment effective date reported to the National Student Clearing House was not reflective of the student?s last date of attendance. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Two instances were identified in 60 students tested. 450 students had status changes during the year. Repeat Finding from Prior Years: No Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-001 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.038 Federal Perkins Loan Program Reporting Material Weakness in Internal Control over Compliance Criteria: 34 CFR 673.3 requires institutions complete the Fiscal Operations Report and Application to Participate (FISAP) to participate in the Federal Perkins Loan Program. The Fiscal Operations Report includes the University?s financial information from the previous award year. Condition: Certain amounts within the FISAP filed during fiscal year 2021 FISAP were reported incorrectly in Part III, Section C, Line 1.1 column (c). Cause: There was a clerical error when typing the number. Effect: Information reported on the FISAP was incorrect. Questioned Costs: None Context/Sampling: Key line items within the FISAP report were tested as required by the OMB Compliance Supplement. No statistical sampling was performed. Repeat Finding from Prior Years: Yes Recommendation: The University should review current processes to ensure that line items reported are accurate. The FISAP review process should include a detail review by an individual independent from the preparer to verify the numbers reported. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-003 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2020/2021 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2020/2021 P063P201430 Reporting? Common Origination and Disbursement System Material Weakness in Internal Control over Compliance and Noncompliance Criteria: An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV, HEA program funds are disbursed on the date that the institution: (a) credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition: Three instances were noted where Title IV funds were applied to the student account but were not processed in COD within the required timeframe. Another two instances were noted where Title IV funds were applied to the student account but were not processed in COD at all. Cause: There was no process in place to monitor and correct denials from the COD system in a timely manner. Effect: COD data was not reflective of the date the aid was applied to the student account. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Five instances were identified in 60 students tested. 290 students received Pell disbursements and 669 students received direct loan disbursements. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure loans applied to student accounts are processed in COD within required time frame and monitor and address denials in a timely manner. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.
2022-004 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2021/2022 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control Criteria: A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution?s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student?s last date of attendance for withdrawals. Condition: Two instances were noted where enrollment effective date reported to the National Student Clearing House as first effective was not the same as the student?s last date of attendance. Cause: The University did not submit the correct last date of attendance to the National Student Clearing House. Effect: Status The enrollment effective date reported to the National Student Clearing House was not reflective of the student?s last date of attendance. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Two instances were identified in 60 students tested. 450 students had status changes during the year. Repeat Finding from Prior Years: No Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.