Audit 328116

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 18 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 18 students who had a change in address, graduated, or withdrew, one was not reported to the NSLDS within the required timeframe. Cause – The College does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the College’s behalf, for completeness and accuracy. We also recommend the College establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date.

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 18 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 18 students who had a change in address, graduated, or withdrew, one was not reported to the NSLDS within the required timeframe. Cause – The College does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the College’s behalf, for completeness and accuracy. We also recommend the College establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date.

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 18 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 18 students who had a change in address, graduated, or withdrew, one was not reported to the NSLDS within the required timeframe. Cause – The College does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the College’s behalf, for completeness and accuracy. We also recommend the College establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date.

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 18 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 18 students who had a change in address, graduated, or withdrew, one was not reported to the NSLDS within the required timeframe. Cause – The College does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the College’s behalf, for completeness and accuracy. We also recommend the College establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date.

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 18 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 18 students who had a change in address, graduated, or withdrew, one was not reported to the NSLDS within the required timeframe. Cause – The College does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the College’s behalf, for completeness and accuracy. We also recommend the College establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date.

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 18 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 18 students who had a change in address, graduated, or withdrew, one was not reported to the NSLDS within the required timeframe. Cause – The College does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the College’s behalf, for completeness and accuracy. We also recommend the College establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date.

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 18 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 18 students who had a change in address, graduated, or withdrew, one was not reported to the NSLDS within the required timeframe. Cause – The College does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the College’s behalf, for completeness and accuracy. We also recommend the College establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date.

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 18 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 18 students who had a change in address, graduated, or withdrew, one was not reported to the NSLDS within the required timeframe. Cause – The College does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the College’s behalf, for completeness and accuracy. We also recommend the College establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date.

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 18 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 18 students who had a change in address, graduated, or withdrew, one was not reported to the NSLDS within the required timeframe. Cause – The College does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the College’s behalf, for completeness and accuracy. We also recommend the College establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date.

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 18 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 18 students who had a change in address, graduated, or withdrew, one was not reported to the NSLDS within the required timeframe. Cause – The College does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the College’s behalf, for completeness and accuracy. We also recommend the College establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date.

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 18 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 18 students who had a change in address, graduated, or withdrew, one was not reported to the NSLDS within the required timeframe. Cause – The College does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the College’s behalf, for completeness and accuracy. We also recommend the College establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date.

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 18 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 18 students who had a change in address, graduated, or withdrew, one was not reported to the NSLDS within the required timeframe. Cause – The College does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the College’s behalf, for completeness and accuracy. We also recommend the College establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date.