Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context: Program Level: Based on a sample of 40 students, 38 students’ enrollment status were not accurately reported to the NSLDS.
Campus Level: Based on a sample of 40 students, 16 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-001.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University experienced significant turnover of staff in the Registrar’s Office in late fiscal year 2023 through fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified during the 2023 fiscal year-end audit; however, the situation was not able to be rectified until well into the 2024 fiscal year.
The University has hired three new permanent staff and an interim registrar, as we search for a permanent registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context: Program Level: Based on a sample of 40 students, 38 students’ enrollment status were not accurately reported to the NSLDS.
Campus Level: Based on a sample of 40 students, 16 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-001.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University experienced significant turnover of staff in the Registrar’s Office in late fiscal year 2023 through fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified during the 2023 fiscal year-end audit; however, the situation was not able to be rectified until well into the 2024 fiscal year.
The University has hired three new permanent staff and an interim registrar, as we search for a permanent registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context: Program Level: Based on a sample of 40 students, 38 students’ enrollment status were not accurately reported to the NSLDS.
Campus Level: Based on a sample of 40 students, 16 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-001.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University experienced significant turnover of staff in the Registrar’s Office in late fiscal year 2023 through fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified during the 2023 fiscal year-end audit; however, the situation was not able to be rectified until well into the 2024 fiscal year.
The University has hired three new permanent staff and an interim registrar, as we search for a permanent registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context: Program Level: Based on a sample of 40 students, 38 students’ enrollment status were not accurately reported to the NSLDS.
Campus Level: Based on a sample of 40 students, 16 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-001.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University experienced significant turnover of staff in the Registrar’s Office in late fiscal year 2023 through fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified during the 2023 fiscal year-end audit; however, the situation was not able to be rectified until well into the 2024 fiscal year.
The University has hired three new permanent staff and an interim registrar, as we search for a permanent registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions –Return of Credit Balances: Federal Regulations require credit balances to returned to students with 14 days of the credit being created on the students account.
Condition: The University did not return credit balances to students within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with federal regulations regarding the timing of return of credit balances.
Questioned Costs: None.
Context: Based on a sample of 40 students, 3 students selected had a credit balance that was not returned within the 14-day period.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-002.
Recommendation: We recommend that the University enhance its procedures to ensure timely return of credit balances to students.
Views of Responsible Officials: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period.
Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them weekly. Additionally, a concerted effort to have the majority of students signed up for eRefund will be made priority.
The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions –Return of Credit Balances: Federal Regulations require credit balances to returned to students with 14 days of the credit being created on the students account.
Condition: The University did not return credit balances to students within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with federal regulations regarding the timing of return of credit balances.
Questioned Costs: None.
Context: Based on a sample of 40 students, 3 students selected had a credit balance that was not returned within the 14-day period.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-002.
Recommendation: We recommend that the University enhance its procedures to ensure timely return of credit balances to students.
Views of Responsible Officials: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period.
Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them weekly. Additionally, a concerted effort to have the majority of students signed up for eRefund will be made priority.
The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions –Return of Credit Balances: Federal Regulations require credit balances to returned to students with 14 days of the credit being created on the students account.
Condition: The University did not return credit balances to students within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with federal regulations regarding the timing of return of credit balances.
Questioned Costs: None.
Context: Based on a sample of 40 students, 3 students selected had a credit balance that was not returned within the 14-day period.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-002.
Recommendation: We recommend that the University enhance its procedures to ensure timely return of credit balances to students.
Views of Responsible Officials: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period.
Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them weekly. Additionally, a concerted effort to have the majority of students signed up for eRefund will be made priority.
The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions –Return of Credit Balances: Federal Regulations require credit balances to returned to students with 14 days of the credit being created on the students account.
Condition: The University did not return credit balances to students within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with federal regulations regarding the timing of return of credit balances.
Questioned Costs: None.
Context: Based on a sample of 40 students, 3 students selected had a credit balance that was not returned within the 14-day period.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-002.
Recommendation: We recommend that the University enhance its procedures to ensure timely return of credit balances to students.
Views of Responsible Officials: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period.
Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them weekly. Additionally, a concerted effort to have the majority of students signed up for eRefund will be made priority.
The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement.
Federal Program Information: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing #84.063).
Criteria or Specific Requirement: C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition: The University had one instance during the year that were identified in which Title IV funds drawn were held in excess of the allowable time frame.
Cause: Administrative oversight.
Effect or Possible Effect: The University is not in compliance with the Cash Management compliance requirements. While amounts were immaterial, certain funds were overdrawn and held in excess of the allowable time frame.
Questioned Costs: Below reporting threshold.
Context: One instance of excess cash that was not eliminated within the allowable time frame was identified for the Federal Pell Grant Program for the year ended May 31, 2024.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend that the University enhance its procedures over cash management to ensure timely elimination of excess cash balances.
Views of Responsible Officials: This is the first time, to the University’s knowledge, that this error has occurred. We believe it was a one-off employee manual oversight, and not a systemic issue. We believe the general procedures for performing the Title IV drawdowns are in good standing; however, we will add a process where the AVP of Business and Finance regularly reviews the Title IV drawdowns to prevent this in the future.
Federal Program Information: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing #84.063).
Criteria or Specific Requirement: L. Reporting – Financial Reporting – Federal regulations require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, COA, and the “Academic Start Date” and “Academic End Date”.
Condition: For certain students identified through our testing, a key item (enrollment date) in student Pell origination records submitted to the COD did not agree to university’s enrollment files.
Cause: Administrative oversight.
Effect or Possible Effect: The University is not in compliance with Pell origination reporting requirements. Failure to accurately update borrower origination information prior to COD submission could result in improper awards of Title IV funds.
Questioned Costs: None.
Context: For 2 of 25 students selected for disbursement testing, the University did not accurately report the student enrollment date to the Department of Education Common Origination and Disbursement website.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University ensure that disbursement records are submitted to COD no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations.
Views of Responsible Officials: The University has evaluated its current practices to confirm student enrollment dates. As a result, the Office of Financial Aid will enhance its policies and procedures for processing Pell grant originations to ensure that accurate enrollment dates are recorded for reporting purposes. These enhancements will include updates to the university’s Pell processing procedures, conducting a simulation of the origination file prior to the official submission to the Common Origination Database (COD), additional training for staff, and implementing periodic secondary reviews.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University did not accurately verify all required information for 2 students.
Cause: Administrative oversight.
Effect or Possible Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 2 of 15 students selected for verification testing, the University did not properly perform verification procedures.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend that the University enhance its procedures to ensure appropriate verification procedures are performed for all students who are selected for verification unless excluded by federal regulations.
Views of Responsible Officials: The University has reviewed its current verification practices. As a result, the Office of Financial Aid will enhance its policies and procedures to ensure accurate verification outcomes. These enhancements will include additional training for financial aid counselors through both internal and external resources, the implementation of the NASFAA Tax Transcript Decoder documentation, and periodic secondary reviews.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University did not accurately verify all required information for 2 students.
Cause: Administrative oversight.
Effect or Possible Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 2 of 15 students selected for verification testing, the University did not properly perform verification procedures.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend that the University enhance its procedures to ensure appropriate verification procedures are performed for all students who are selected for verification unless excluded by federal regulations.
Views of Responsible Officials: The University has reviewed its current verification practices. As a result, the Office of Financial Aid will enhance its policies and procedures to ensure accurate verification outcomes. These enhancements will include additional training for financial aid counselors through both internal and external resources, the implementation of the NASFAA Tax Transcript Decoder documentation, and periodic secondary reviews.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University did not accurately verify all required information for 2 students.
Cause: Administrative oversight.
Effect or Possible Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 2 of 15 students selected for verification testing, the University did not properly perform verification procedures.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend that the University enhance its procedures to ensure appropriate verification procedures are performed for all students who are selected for verification unless excluded by federal regulations.
Views of Responsible Officials: The University has reviewed its current verification practices. As a result, the Office of Financial Aid will enhance its policies and procedures to ensure accurate verification outcomes. These enhancements will include additional training for financial aid counselors through both internal and external resources, the implementation of the NASFAA Tax Transcript Decoder documentation, and periodic secondary reviews.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University did not accurately verify all required information for 2 students.
Cause: Administrative oversight.
Effect or Possible Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 2 of 15 students selected for verification testing, the University did not properly perform verification procedures.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend that the University enhance its procedures to ensure appropriate verification procedures are performed for all students who are selected for verification unless excluded by federal regulations.
Views of Responsible Officials: The University has reviewed its current verification practices. As a result, the Office of Financial Aid will enhance its policies and procedures to ensure accurate verification outcomes. These enhancements will include additional training for financial aid counselors through both internal and external resources, the implementation of the NASFAA Tax Transcript Decoder documentation, and periodic secondary reviews.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context: Program Level: Based on a sample of 40 students, 38 students’ enrollment status were not accurately reported to the NSLDS.
Campus Level: Based on a sample of 40 students, 16 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-001.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University experienced significant turnover of staff in the Registrar’s Office in late fiscal year 2023 through fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified during the 2023 fiscal year-end audit; however, the situation was not able to be rectified until well into the 2024 fiscal year.
The University has hired three new permanent staff and an interim registrar, as we search for a permanent registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context: Program Level: Based on a sample of 40 students, 38 students’ enrollment status were not accurately reported to the NSLDS.
Campus Level: Based on a sample of 40 students, 16 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-001.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University experienced significant turnover of staff in the Registrar’s Office in late fiscal year 2023 through fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified during the 2023 fiscal year-end audit; however, the situation was not able to be rectified until well into the 2024 fiscal year.
The University has hired three new permanent staff and an interim registrar, as we search for a permanent registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context: Program Level: Based on a sample of 40 students, 38 students’ enrollment status were not accurately reported to the NSLDS.
Campus Level: Based on a sample of 40 students, 16 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-001.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University experienced significant turnover of staff in the Registrar’s Office in late fiscal year 2023 through fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified during the 2023 fiscal year-end audit; however, the situation was not able to be rectified until well into the 2024 fiscal year.
The University has hired three new permanent staff and an interim registrar, as we search for a permanent registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context: Program Level: Based on a sample of 40 students, 38 students’ enrollment status were not accurately reported to the NSLDS.
Campus Level: Based on a sample of 40 students, 16 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-001.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University experienced significant turnover of staff in the Registrar’s Office in late fiscal year 2023 through fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified during the 2023 fiscal year-end audit; however, the situation was not able to be rectified until well into the 2024 fiscal year.
The University has hired three new permanent staff and an interim registrar, as we search for a permanent registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions –Return of Credit Balances: Federal Regulations require credit balances to returned to students with 14 days of the credit being created on the students account.
Condition: The University did not return credit balances to students within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with federal regulations regarding the timing of return of credit balances.
Questioned Costs: None.
Context: Based on a sample of 40 students, 3 students selected had a credit balance that was not returned within the 14-day period.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-002.
Recommendation: We recommend that the University enhance its procedures to ensure timely return of credit balances to students.
Views of Responsible Officials: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period.
Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them weekly. Additionally, a concerted effort to have the majority of students signed up for eRefund will be made priority.
The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions –Return of Credit Balances: Federal Regulations require credit balances to returned to students with 14 days of the credit being created on the students account.
Condition: The University did not return credit balances to students within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with federal regulations regarding the timing of return of credit balances.
Questioned Costs: None.
Context: Based on a sample of 40 students, 3 students selected had a credit balance that was not returned within the 14-day period.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-002.
Recommendation: We recommend that the University enhance its procedures to ensure timely return of credit balances to students.
Views of Responsible Officials: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period.
Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them weekly. Additionally, a concerted effort to have the majority of students signed up for eRefund will be made priority.
The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions –Return of Credit Balances: Federal Regulations require credit balances to returned to students with 14 days of the credit being created on the students account.
Condition: The University did not return credit balances to students within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with federal regulations regarding the timing of return of credit balances.
Questioned Costs: None.
Context: Based on a sample of 40 students, 3 students selected had a credit balance that was not returned within the 14-day period.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-002.
Recommendation: We recommend that the University enhance its procedures to ensure timely return of credit balances to students.
Views of Responsible Officials: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period.
Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them weekly. Additionally, a concerted effort to have the majority of students signed up for eRefund will be made priority.
The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions –Return of Credit Balances: Federal Regulations require credit balances to returned to students with 14 days of the credit being created on the students account.
Condition: The University did not return credit balances to students within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with federal regulations regarding the timing of return of credit balances.
Questioned Costs: None.
Context: Based on a sample of 40 students, 3 students selected had a credit balance that was not returned within the 14-day period.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-002.
Recommendation: We recommend that the University enhance its procedures to ensure timely return of credit balances to students.
Views of Responsible Officials: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period.
Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them weekly. Additionally, a concerted effort to have the majority of students signed up for eRefund will be made priority.
The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement.
Federal Program Information: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing #84.063).
Criteria or Specific Requirement: C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition: The University had one instance during the year that were identified in which Title IV funds drawn were held in excess of the allowable time frame.
Cause: Administrative oversight.
Effect or Possible Effect: The University is not in compliance with the Cash Management compliance requirements. While amounts were immaterial, certain funds were overdrawn and held in excess of the allowable time frame.
Questioned Costs: Below reporting threshold.
Context: One instance of excess cash that was not eliminated within the allowable time frame was identified for the Federal Pell Grant Program for the year ended May 31, 2024.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend that the University enhance its procedures over cash management to ensure timely elimination of excess cash balances.
Views of Responsible Officials: This is the first time, to the University’s knowledge, that this error has occurred. We believe it was a one-off employee manual oversight, and not a systemic issue. We believe the general procedures for performing the Title IV drawdowns are in good standing; however, we will add a process where the AVP of Business and Finance regularly reviews the Title IV drawdowns to prevent this in the future.
Federal Program Information: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing #84.063).
Criteria or Specific Requirement: L. Reporting – Financial Reporting – Federal regulations require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, COA, and the “Academic Start Date” and “Academic End Date”.
Condition: For certain students identified through our testing, a key item (enrollment date) in student Pell origination records submitted to the COD did not agree to university’s enrollment files.
Cause: Administrative oversight.
Effect or Possible Effect: The University is not in compliance with Pell origination reporting requirements. Failure to accurately update borrower origination information prior to COD submission could result in improper awards of Title IV funds.
Questioned Costs: None.
Context: For 2 of 25 students selected for disbursement testing, the University did not accurately report the student enrollment date to the Department of Education Common Origination and Disbursement website.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University ensure that disbursement records are submitted to COD no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations.
Views of Responsible Officials: The University has evaluated its current practices to confirm student enrollment dates. As a result, the Office of Financial Aid will enhance its policies and procedures for processing Pell grant originations to ensure that accurate enrollment dates are recorded for reporting purposes. These enhancements will include updates to the university’s Pell processing procedures, conducting a simulation of the origination file prior to the official submission to the Common Origination Database (COD), additional training for staff, and implementing periodic secondary reviews.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University did not accurately verify all required information for 2 students.
Cause: Administrative oversight.
Effect or Possible Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 2 of 15 students selected for verification testing, the University did not properly perform verification procedures.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend that the University enhance its procedures to ensure appropriate verification procedures are performed for all students who are selected for verification unless excluded by federal regulations.
Views of Responsible Officials: The University has reviewed its current verification practices. As a result, the Office of Financial Aid will enhance its policies and procedures to ensure accurate verification outcomes. These enhancements will include additional training for financial aid counselors through both internal and external resources, the implementation of the NASFAA Tax Transcript Decoder documentation, and periodic secondary reviews.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University did not accurately verify all required information for 2 students.
Cause: Administrative oversight.
Effect or Possible Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 2 of 15 students selected for verification testing, the University did not properly perform verification procedures.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend that the University enhance its procedures to ensure appropriate verification procedures are performed for all students who are selected for verification unless excluded by federal regulations.
Views of Responsible Officials: The University has reviewed its current verification practices. As a result, the Office of Financial Aid will enhance its policies and procedures to ensure accurate verification outcomes. These enhancements will include additional training for financial aid counselors through both internal and external resources, the implementation of the NASFAA Tax Transcript Decoder documentation, and periodic secondary reviews.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University did not accurately verify all required information for 2 students.
Cause: Administrative oversight.
Effect or Possible Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 2 of 15 students selected for verification testing, the University did not properly perform verification procedures.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend that the University enhance its procedures to ensure appropriate verification procedures are performed for all students who are selected for verification unless excluded by federal regulations.
Views of Responsible Officials: The University has reviewed its current verification practices. As a result, the Office of Financial Aid will enhance its policies and procedures to ensure accurate verification outcomes. These enhancements will include additional training for financial aid counselors through both internal and external resources, the implementation of the NASFAA Tax Transcript Decoder documentation, and periodic secondary reviews.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University did not accurately verify all required information for 2 students.
Cause: Administrative oversight.
Effect or Possible Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 2 of 15 students selected for verification testing, the University did not properly perform verification procedures.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend that the University enhance its procedures to ensure appropriate verification procedures are performed for all students who are selected for verification unless excluded by federal regulations.
Views of Responsible Officials: The University has reviewed its current verification practices. As a result, the Office of Financial Aid will enhance its policies and procedures to ensure accurate verification outcomes. These enhancements will include additional training for financial aid counselors through both internal and external resources, the implementation of the NASFAA Tax Transcript Decoder documentation, and periodic secondary reviews.