Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information.
Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS).
Questioned costs – $0
Context – Out of the population of 829 students with student attendance changes required to be reported, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change.
Campus-Level Records:
1. OPEID Number
2. Enrollment Effective Date
3. Enrollment Status
4. Certification Date
Program-Level Records
5. OPEID
6. CIP Code
7. CIP Year
8. Credential Level
9. Published Program Length Measurement
10. Published Program Length
11. Program Begin Date
12. Program Enrollment Status
13. Program Enrollment Effective Date
Other Records
14. Student changed his or her permanent address
The University failed to report 3 students who had changes in enrollment status. Of the three students the University failed to report, 2 students had withdrawn from the University. The University reported the incorrect enrollment effective dates for 3 students at the program and campus levels. The University failed to report graduated status for 2 students (students were reported as withdrawn and the University failed to subsequently update the status to graduated). The University reported the incorrect Program Enrollment Effective Date for 1 student. The University did not report a change in enrollment status in a timely manner for 1 student.
Effect – The University failed to report students' status changes, and did not report the status changes timely.
Cause – The University’s processes did not ensure status changes were reported timely and accurately.
Identification as repeat finding, if applicable – 2023-001 and 2022-001
Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner.
Views of responsible officials, reason for recurrence, and planned corrective actions – Management acknowledges and understands the findings associated with the lack of reporting enrollment changes. Due to the nature and timing of the findings, the University has begun the process of additional review within Banner ERP systems and reconciliation of the times being reported for mid-term changes. By doing so, the university plans to resolve any future misalignment of enrollment change dates between the Banner ERP system, Clearing House, and NSLDS.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information.
Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS).
Questioned costs – $0
Context – Out of the population of 829 students with student attendance changes required to be reported, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change.
Campus-Level Records:
1. OPEID Number
2. Enrollment Effective Date
3. Enrollment Status
4. Certification Date
Program-Level Records
5. OPEID
6. CIP Code
7. CIP Year
8. Credential Level
9. Published Program Length Measurement
10. Published Program Length
11. Program Begin Date
12. Program Enrollment Status
13. Program Enrollment Effective Date
Other Records
14. Student changed his or her permanent address
The University failed to report 3 students who had changes in enrollment status. Of the three students the University failed to report, 2 students had withdrawn from the University. The University reported the incorrect enrollment effective dates for 3 students at the program and campus levels. The University failed to report graduated status for 2 students (students were reported as withdrawn and the University failed to subsequently update the status to graduated). The University reported the incorrect Program Enrollment Effective Date for 1 student. The University did not report a change in enrollment status in a timely manner for 1 student.
Effect – The University failed to report students' status changes, and did not report the status changes timely.
Cause – The University’s processes did not ensure status changes were reported timely and accurately.
Identification as repeat finding, if applicable – 2023-001 and 2022-001
Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner.
Views of responsible officials, reason for recurrence, and planned corrective actions – Management acknowledges and understands the findings associated with the lack of reporting enrollment changes. Due to the nature and timing of the findings, the University has begun the process of additional review within Banner ERP systems and reconciliation of the times being reported for mid-term changes. By doing so, the university plans to resolve any future misalignment of enrollment change dates between the Banner ERP system, Clearing House, and NSLDS.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033
Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.
Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation.
Questioned costs – $2,000
Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid.
Effect – the University was not in compliance with its PPA during the year.
Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted.
Identification as repeat finding, if applicable – N/A
Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA.
Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033
Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.
Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation.
Questioned costs – $2,000
Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid.
Effect – the University was not in compliance with its PPA during the year.
Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted.
Identification as repeat finding, if applicable – N/A
Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA.
Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033
Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.
Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation.
Questioned costs – $2,000
Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid.
Effect – the University was not in compliance with its PPA during the year.
Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted.
Identification as repeat finding, if applicable – N/A
Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA.
Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033
Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.
Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation.
Questioned costs – $2,000
Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid.
Effect – the University was not in compliance with its PPA during the year.
Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted.
Identification as repeat finding, if applicable – N/A
Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA.
Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033
Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.
Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation.
Questioned costs – $2,000
Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid.
Effect – the University was not in compliance with its PPA during the year.
Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted.
Identification as repeat finding, if applicable – N/A
Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA.
Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information.
Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS).
Questioned costs – $0
Context – Out of the population of 829 students with student attendance changes required to be reported, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change.
Campus-Level Records:
1. OPEID Number
2. Enrollment Effective Date
3. Enrollment Status
4. Certification Date
Program-Level Records
5. OPEID
6. CIP Code
7. CIP Year
8. Credential Level
9. Published Program Length Measurement
10. Published Program Length
11. Program Begin Date
12. Program Enrollment Status
13. Program Enrollment Effective Date
Other Records
14. Student changed his or her permanent address
The University failed to report 3 students who had changes in enrollment status. Of the three students the University failed to report, 2 students had withdrawn from the University. The University reported the incorrect enrollment effective dates for 3 students at the program and campus levels. The University failed to report graduated status for 2 students (students were reported as withdrawn and the University failed to subsequently update the status to graduated). The University reported the incorrect Program Enrollment Effective Date for 1 student. The University did not report a change in enrollment status in a timely manner for 1 student.
Effect – The University failed to report students' status changes, and did not report the status changes timely.
Cause – The University’s processes did not ensure status changes were reported timely and accurately.
Identification as repeat finding, if applicable – 2023-001 and 2022-001
Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner.
Views of responsible officials, reason for recurrence, and planned corrective actions – Management acknowledges and understands the findings associated with the lack of reporting enrollment changes. Due to the nature and timing of the findings, the University has begun the process of additional review within Banner ERP systems and reconciliation of the times being reported for mid-term changes. By doing so, the university plans to resolve any future misalignment of enrollment change dates between the Banner ERP system, Clearing House, and NSLDS.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information.
Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS).
Questioned costs – $0
Context – Out of the population of 829 students with student attendance changes required to be reported, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change.
Campus-Level Records:
1. OPEID Number
2. Enrollment Effective Date
3. Enrollment Status
4. Certification Date
Program-Level Records
5. OPEID
6. CIP Code
7. CIP Year
8. Credential Level
9. Published Program Length Measurement
10. Published Program Length
11. Program Begin Date
12. Program Enrollment Status
13. Program Enrollment Effective Date
Other Records
14. Student changed his or her permanent address
The University failed to report 3 students who had changes in enrollment status. Of the three students the University failed to report, 2 students had withdrawn from the University. The University reported the incorrect enrollment effective dates for 3 students at the program and campus levels. The University failed to report graduated status for 2 students (students were reported as withdrawn and the University failed to subsequently update the status to graduated). The University reported the incorrect Program Enrollment Effective Date for 1 student. The University did not report a change in enrollment status in a timely manner for 1 student.
Effect – The University failed to report students' status changes, and did not report the status changes timely.
Cause – The University’s processes did not ensure status changes were reported timely and accurately.
Identification as repeat finding, if applicable – 2023-001 and 2022-001
Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner.
Views of responsible officials, reason for recurrence, and planned corrective actions – Management acknowledges and understands the findings associated with the lack of reporting enrollment changes. Due to the nature and timing of the findings, the University has begun the process of additional review within Banner ERP systems and reconciliation of the times being reported for mid-term changes. By doing so, the university plans to resolve any future misalignment of enrollment change dates between the Banner ERP system, Clearing House, and NSLDS.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033
Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.
Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation.
Questioned costs – $2,000
Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid.
Effect – the University was not in compliance with its PPA during the year.
Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted.
Identification as repeat finding, if applicable – N/A
Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA.
Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033
Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.
Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation.
Questioned costs – $2,000
Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid.
Effect – the University was not in compliance with its PPA during the year.
Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted.
Identification as repeat finding, if applicable – N/A
Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA.
Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033
Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.
Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation.
Questioned costs – $2,000
Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid.
Effect – the University was not in compliance with its PPA during the year.
Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted.
Identification as repeat finding, if applicable – N/A
Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA.
Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033
Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.
Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation.
Questioned costs – $2,000
Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid.
Effect – the University was not in compliance with its PPA during the year.
Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted.
Identification as repeat finding, if applicable – N/A
Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA.
Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033
Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.
Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation.
Questioned costs – $2,000
Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid.
Effect – the University was not in compliance with its PPA during the year.
Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted.
Identification as repeat finding, if applicable – N/A
Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA.
Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.