2024-003 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003 and 2023-004)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $20 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office continued with the calendar process showing days of attendance
from the first day of school to the last using the school’s master calendar as a reference. This will be
used also as a double check of days when calculating returns. The dates used in the return
calculations were off a day due to misreading the ending date of semester. The Financial Aid
Administrator verified the beginning and last day of each semester with the Registrar’s office in
writing.
2024-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2023-005)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $1,984 under-awarded. Extrapolation of the error
was not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University has enhanced the process of completing return to Title
IV calculations by incorporating additional training and workshops provided by the Department of
Education. The financial aid office has continued with the implementation of the calendar that
displays the attendance days from the first day of school to the last day of school, referring to the
school’s master calendar. The financial aid office added an extra verification step of written
notification from the Registrar’s office of beginning and end days for each semester. The return
calculations were one day off due to the misinterpretation of the semester’s ending date.
2024-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(i), unearned funds returned by the institution or the
student, as appropriate, must be credited to outstanding balances on Title IV loans made to the
student or on behalf of the student for the payment period or period of enrollment for which a
return of funds is required. Those funds must be credited to outstanding balances for the payment
period or period of enrollment for which a return of funds is required in the following order: (i)
Unsubsidized Federal Direct Stafford loans, (ii) Subsidized Federal Direct Stafford loans, (iii) Federal
Direct PLUS received on behalf of the student. If unearned funds remain to be returned after
repayment of all outstanding loan amounts, the remaining excess must be credited to any amount
awarded for the payment period or period of enrollment for which a return of funds is required in
the following order: (i) Federal Pell Grants, (ii) Iraq and Afghanistan Service Grants, (iii) FSEOG
Program aid, (iv) TEACH Grants.
Statement of Condition: During the audit, it was noted that the University returned funds in an
incorrect sequence during the Return to Title IV Funds process upon student withdrawal.
Questioned Costs: There is no known monetary error as the mistake causes a misclassification in
type of award, but net award amount is not affected.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 2, indicating an error rate of 100%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the institution applied the percentage of
earned aid to each type of disbursed aid individually, returning the remaining portion of each type
of aid. However, the guidance stipulates that funds should be returned in a set order, returning the
full amount of each type before moving to the next.
In the return to Title IV process for the first student, the institution calculated an earned percentage
of 50.0% based upon completed days. The student had been disbursed both subsidized and
unsubsidized loans for the term. The director applied the 50.0% to each subsidized and unsubsidized
awards to determine the monetary amounts of earned aid, returning the remaining $495 of
subsidized and $866 unsubsidized loan disbursements to G5. The appropriate treatment would have
been to return the full unearned portion of aid from the unsubsidized award.
In the return to Title IV process for the second student, the institution calculated an earned
percentage of 42.2% based upon completed days. The student had been disbursed both Pell and
FSEOG for the term. The director applied the 42.2% to each Pell and FSEOG awards to determine the
monetary amounts of earned aid, returning the remaining $2,156 of Pell and $146 of FSEOG
disbursements to G5. The appropriate treatment would have been to return the full unearned
portion of aid from the Pell award.
Recommendation: The University should ensure that funds are returned in the prescribed sequence
in the determination of the return of aid as designated by the Compliance Supplement and the
Student Financial Aid Handbook.
View of Responsible Officials: The University’s Vice President of Finance and Financial Aid
Administrator recently attended a week-long workshop and received training to complete the R2T4
calculation via COD. The training was received after the infringements and a plan has been adapted
to utilize COD for future R2T4 calculations and sequence. The school calendar has been updated in
COD for correct future calculations and sequence.
2024-003 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003 and 2023-004)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $20 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office continued with the calendar process showing days of attendance
from the first day of school to the last using the school’s master calendar as a reference. This will be
used also as a double check of days when calculating returns. The dates used in the return
calculations were off a day due to misreading the ending date of semester. The Financial Aid
Administrator verified the beginning and last day of each semester with the Registrar’s office in
writing.
2024-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2023-005)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $1,984 under-awarded. Extrapolation of the error
was not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University has enhanced the process of completing return to Title
IV calculations by incorporating additional training and workshops provided by the Department of
Education. The financial aid office has continued with the implementation of the calendar that
displays the attendance days from the first day of school to the last day of school, referring to the
school’s master calendar. The financial aid office added an extra verification step of written
notification from the Registrar’s office of beginning and end days for each semester. The return
calculations were one day off due to the misinterpretation of the semester’s ending date.
2024-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(i), unearned funds returned by the institution or the
student, as appropriate, must be credited to outstanding balances on Title IV loans made to the
student or on behalf of the student for the payment period or period of enrollment for which a
return of funds is required. Those funds must be credited to outstanding balances for the payment
period or period of enrollment for which a return of funds is required in the following order: (i)
Unsubsidized Federal Direct Stafford loans, (ii) Subsidized Federal Direct Stafford loans, (iii) Federal
Direct PLUS received on behalf of the student. If unearned funds remain to be returned after
repayment of all outstanding loan amounts, the remaining excess must be credited to any amount
awarded for the payment period or period of enrollment for which a return of funds is required in
the following order: (i) Federal Pell Grants, (ii) Iraq and Afghanistan Service Grants, (iii) FSEOG
Program aid, (iv) TEACH Grants.
Statement of Condition: During the audit, it was noted that the University returned funds in an
incorrect sequence during the Return to Title IV Funds process upon student withdrawal.
Questioned Costs: There is no known monetary error as the mistake causes a misclassification in
type of award, but net award amount is not affected.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 2, indicating an error rate of 100%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the institution applied the percentage of
earned aid to each type of disbursed aid individually, returning the remaining portion of each type
of aid. However, the guidance stipulates that funds should be returned in a set order, returning the
full amount of each type before moving to the next.
In the return to Title IV process for the first student, the institution calculated an earned percentage
of 50.0% based upon completed days. The student had been disbursed both subsidized and
unsubsidized loans for the term. The director applied the 50.0% to each subsidized and unsubsidized
awards to determine the monetary amounts of earned aid, returning the remaining $495 of
subsidized and $866 unsubsidized loan disbursements to G5. The appropriate treatment would have
been to return the full unearned portion of aid from the unsubsidized award.
In the return to Title IV process for the second student, the institution calculated an earned
percentage of 42.2% based upon completed days. The student had been disbursed both Pell and
FSEOG for the term. The director applied the 42.2% to each Pell and FSEOG awards to determine the
monetary amounts of earned aid, returning the remaining $2,156 of Pell and $146 of FSEOG
disbursements to G5. The appropriate treatment would have been to return the full unearned
portion of aid from the Pell award.
Recommendation: The University should ensure that funds are returned in the prescribed sequence
in the determination of the return of aid as designated by the Compliance Supplement and the
Student Financial Aid Handbook.
View of Responsible Officials: The University’s Vice President of Finance and Financial Aid
Administrator recently attended a week-long workshop and received training to complete the R2T4
calculation via COD. The training was received after the infringements and a plan has been adapted
to utilize COD for future R2T4 calculations and sequence. The school calendar has been updated in
COD for correct future calculations and sequence.
2024-002 Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education,
William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding 2023-002)
Criteria: In accordance with 16 CFR 314.4, a University shall develop, implement, and maintain a
comprehensive information security program that is written in one or more readily accessible parts
and contains administrative, technical, and physical safeguards that are appropriate to your size and
complexity, the nature and scope of your activities, and the sensitivity of any customer information
at issue and must contain all of the elements that are further described in 16 CFR 314.4.
Statement of Condition: During the audit, it was noted that the University’s Gramm-Leach-Bliley Act
Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the
application of the comprehensive information security program was not effectively administered by
the University during the 2024 year. An updated policy was put into place in February 2024, which
addressed several of the deficiencies noted in the existing policy, but not all.
The seven required elements for the GLBA policy are as follows, along with the status within each of
the University’s policies in place during the year:
1. The policy designates a qualified individual responsible for overseeing and implementing the
institution’s information security program and enforcing the information security program in
compliance.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement, identifying a GLBA Compliance Program Coordinator responsible for
the listed functions.
2. The policy provides for the information security program to be based on a risk assessment that
identifies reasonably foreseeable internal and external risks to the security, confidentiality, and
integrity of customer information (as the term customer information applies to the institution)
that could result in the unauthorized disclosure, misuse, alteration, destruction, or other
compromise of such information, and assesses the sufficiency of any safeguards in place to
control these risks.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement.
3. The policy provides for the design and implementation of safeguards to control the risks the
institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the
institution’s written information security program must address the implementation of the
minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), which are detailed as follows:
3.1. Implement and periodically review access controls.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement, instituting a continuous monitoring process undertaken at
periodic intervals. The timeframe of the periodic intervals is not defined.
3.2. Conduct a periodic inventory of data, noting where it is collected, stored or transmitted.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement. They will utilize data mapping to complete this process.
However, the institution was unable to provide a date of the last inventory completed.
3.3. Encrypt customer information on the institution’s system and when it is in transit.
Both the existing policy and the newly implemented policy are silent on this requirement.
3.4. Assess applications developed by the institution.
Both the existing policy and the newly implemented policy are silent on this requirement.
3.5. Implement multi-factor authentication for anyone accessing customer information on the
institution’s system.
Both the existing policy and the newly implemented policy are silent on this requirement.
3.6. Dispose of customer information securely.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement. The new policy provides a link to the information regarding
retention and destruction of documents.
3.7. Anticipate and evaluate changes to the information system or network.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement.
3.8. Maintain a log of authorized users’ activity and keep an eye out for unauthorized access.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement. The policy provides a link to the acceptable use policy.
4. The policy provides for the institution to regularly test or otherwise monitor the effectiveness of
the safeguards it has implemented.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement, instituting a continuous monitoring process undertaken at periodic
intervals. The timeframe of the periodic intervals is not defined.
5. The policy provides for the implementation of policies and procedures to ensure that personnel
are able to enact the information security program.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement, identifying the IT department in collaboration with the VP of finance
as the responsible parties for this process.
6. The policy addresses how the institution will oversee its information system service providers.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement. The program coordinator has been tasked with this activity in
conjunction with the VP of Finance.
7. The policy provides for the evaluation and adjustment of its information security program in
light of the results of the required testing and monitoring; any material changes to its operations
or business arrangements; the results of the required risk assessments; or any other
circumstances that it knows or has reason to know may have a material impact the institution’s
information security program.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement. The policy will be reviewed annually at a minimum.
Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in
nature.
Perspective Information: The audit included testing of the University’s Gramm-Leach-Bliley Act
Policy as outlined in Part 5 of the Compliance Supplement including the application of this program
for the year.
Cause and Effect: Due to lapses of oversight in multiple departments, the University failed to update
their GLBA policy in a timely manner to include the required components in accordance with the
Compliance Supplement. The University implemented an updated policy in February 2024. Both the
previous policy and updated policy were subjected to audit procedures, and several requirements
were missing from both policies. Therefore, the policy is considered incomplete and does not
provide the appropriate disclosures to consumers.
Recommendation: The University should update their Gramm-Leach-Bliley Act Policy to be in
accordance with the requirements and put in place effective controls and practices to ensure the
policy is monitored in a way to ensure it is administered effectively.
View of Responsible Officials: The University recently reviewed the Gramm-Leach-Bliley Act Policy
and has put in place controls and practices to effectively monitor and administer the policy. In April
2024, we hired an IT company to help with various campus needs, including data compliance
procedures and security measures. The company has been reviewing our current policies and
making recommendations to implement appropriate safeguards to keep the university up to date
and compliant. We have already installed multi-factor authentication features for our software
systems, and there are more updates to come. In July 2024, we received a notice of compliance
from the Federal Student Aid regarding our corrective action procedures for the Gramm-Leach-Bliley
Act.
2024-003 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003 and 2023-004)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $20 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office continued with the calendar process showing days of attendance
from the first day of school to the last using the school’s master calendar as a reference. This will be
used also as a double check of days when calculating returns. The dates used in the return
calculations were off a day due to misreading the ending date of semester. The Financial Aid
Administrator verified the beginning and last day of each semester with the Registrar’s office in
writing.
2024-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2023-005)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $1,984 under-awarded. Extrapolation of the error
was not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University has enhanced the process of completing return to Title
IV calculations by incorporating additional training and workshops provided by the Department of
Education. The financial aid office has continued with the implementation of the calendar that
displays the attendance days from the first day of school to the last day of school, referring to the
school’s master calendar. The financial aid office added an extra verification step of written
notification from the Registrar’s office of beginning and end days for each semester. The return
calculations were one day off due to the misinterpretation of the semester’s ending date.
2024-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(i), unearned funds returned by the institution or the
student, as appropriate, must be credited to outstanding balances on Title IV loans made to the
student or on behalf of the student for the payment period or period of enrollment for which a
return of funds is required. Those funds must be credited to outstanding balances for the payment
period or period of enrollment for which a return of funds is required in the following order: (i)
Unsubsidized Federal Direct Stafford loans, (ii) Subsidized Federal Direct Stafford loans, (iii) Federal
Direct PLUS received on behalf of the student. If unearned funds remain to be returned after
repayment of all outstanding loan amounts, the remaining excess must be credited to any amount
awarded for the payment period or period of enrollment for which a return of funds is required in
the following order: (i) Federal Pell Grants, (ii) Iraq and Afghanistan Service Grants, (iii) FSEOG
Program aid, (iv) TEACH Grants.
Statement of Condition: During the audit, it was noted that the University returned funds in an
incorrect sequence during the Return to Title IV Funds process upon student withdrawal.
Questioned Costs: There is no known monetary error as the mistake causes a misclassification in
type of award, but net award amount is not affected.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 2, indicating an error rate of 100%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the institution applied the percentage of
earned aid to each type of disbursed aid individually, returning the remaining portion of each type
of aid. However, the guidance stipulates that funds should be returned in a set order, returning the
full amount of each type before moving to the next.
In the return to Title IV process for the first student, the institution calculated an earned percentage
of 50.0% based upon completed days. The student had been disbursed both subsidized and
unsubsidized loans for the term. The director applied the 50.0% to each subsidized and unsubsidized
awards to determine the monetary amounts of earned aid, returning the remaining $495 of
subsidized and $866 unsubsidized loan disbursements to G5. The appropriate treatment would have
been to return the full unearned portion of aid from the unsubsidized award.
In the return to Title IV process for the second student, the institution calculated an earned
percentage of 42.2% based upon completed days. The student had been disbursed both Pell and
FSEOG for the term. The director applied the 42.2% to each Pell and FSEOG awards to determine the
monetary amounts of earned aid, returning the remaining $2,156 of Pell and $146 of FSEOG
disbursements to G5. The appropriate treatment would have been to return the full unearned
portion of aid from the Pell award.
Recommendation: The University should ensure that funds are returned in the prescribed sequence
in the determination of the return of aid as designated by the Compliance Supplement and the
Student Financial Aid Handbook.
View of Responsible Officials: The University’s Vice President of Finance and Financial Aid
Administrator recently attended a week-long workshop and received training to complete the R2T4
calculation via COD. The training was received after the infringements and a plan has been adapted
to utilize COD for future R2T4 calculations and sequence. The school calendar has been updated in
COD for correct future calculations and sequence.
2024-003 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003 and 2023-004)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $20 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office continued with the calendar process showing days of attendance
from the first day of school to the last using the school’s master calendar as a reference. This will be
used also as a double check of days when calculating returns. The dates used in the return
calculations were off a day due to misreading the ending date of semester. The Financial Aid
Administrator verified the beginning and last day of each semester with the Registrar’s office in
writing.
2024-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2023-005)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $1,984 under-awarded. Extrapolation of the error
was not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University has enhanced the process of completing return to Title
IV calculations by incorporating additional training and workshops provided by the Department of
Education. The financial aid office has continued with the implementation of the calendar that
displays the attendance days from the first day of school to the last day of school, referring to the
school’s master calendar. The financial aid office added an extra verification step of written
notification from the Registrar’s office of beginning and end days for each semester. The return
calculations were one day off due to the misinterpretation of the semester’s ending date.
2024-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(i), unearned funds returned by the institution or the
student, as appropriate, must be credited to outstanding balances on Title IV loans made to the
student or on behalf of the student for the payment period or period of enrollment for which a
return of funds is required. Those funds must be credited to outstanding balances for the payment
period or period of enrollment for which a return of funds is required in the following order: (i)
Unsubsidized Federal Direct Stafford loans, (ii) Subsidized Federal Direct Stafford loans, (iii) Federal
Direct PLUS received on behalf of the student. If unearned funds remain to be returned after
repayment of all outstanding loan amounts, the remaining excess must be credited to any amount
awarded for the payment period or period of enrollment for which a return of funds is required in
the following order: (i) Federal Pell Grants, (ii) Iraq and Afghanistan Service Grants, (iii) FSEOG
Program aid, (iv) TEACH Grants.
Statement of Condition: During the audit, it was noted that the University returned funds in an
incorrect sequence during the Return to Title IV Funds process upon student withdrawal.
Questioned Costs: There is no known monetary error as the mistake causes a misclassification in
type of award, but net award amount is not affected.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 2, indicating an error rate of 100%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the institution applied the percentage of
earned aid to each type of disbursed aid individually, returning the remaining portion of each type
of aid. However, the guidance stipulates that funds should be returned in a set order, returning the
full amount of each type before moving to the next.
In the return to Title IV process for the first student, the institution calculated an earned percentage
of 50.0% based upon completed days. The student had been disbursed both subsidized and
unsubsidized loans for the term. The director applied the 50.0% to each subsidized and unsubsidized
awards to determine the monetary amounts of earned aid, returning the remaining $495 of
subsidized and $866 unsubsidized loan disbursements to G5. The appropriate treatment would have
been to return the full unearned portion of aid from the unsubsidized award.
In the return to Title IV process for the second student, the institution calculated an earned
percentage of 42.2% based upon completed days. The student had been disbursed both Pell and
FSEOG for the term. The director applied the 42.2% to each Pell and FSEOG awards to determine the
monetary amounts of earned aid, returning the remaining $2,156 of Pell and $146 of FSEOG
disbursements to G5. The appropriate treatment would have been to return the full unearned
portion of aid from the Pell award.
Recommendation: The University should ensure that funds are returned in the prescribed sequence
in the determination of the return of aid as designated by the Compliance Supplement and the
Student Financial Aid Handbook.
View of Responsible Officials: The University’s Vice President of Finance and Financial Aid
Administrator recently attended a week-long workshop and received training to complete the R2T4
calculation via COD. The training was received after the infringements and a plan has been adapted
to utilize COD for future R2T4 calculations and sequence. The school calendar has been updated in
COD for correct future calculations and sequence.
2024-003 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003 and 2023-004)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $20 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office continued with the calendar process showing days of attendance
from the first day of school to the last using the school’s master calendar as a reference. This will be
used also as a double check of days when calculating returns. The dates used in the return
calculations were off a day due to misreading the ending date of semester. The Financial Aid
Administrator verified the beginning and last day of each semester with the Registrar’s office in
writing.
2024-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2023-005)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $1,984 under-awarded. Extrapolation of the error
was not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University has enhanced the process of completing return to Title
IV calculations by incorporating additional training and workshops provided by the Department of
Education. The financial aid office has continued with the implementation of the calendar that
displays the attendance days from the first day of school to the last day of school, referring to the
school’s master calendar. The financial aid office added an extra verification step of written
notification from the Registrar’s office of beginning and end days for each semester. The return
calculations were one day off due to the misinterpretation of the semester’s ending date.
2024-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(i), unearned funds returned by the institution or the
student, as appropriate, must be credited to outstanding balances on Title IV loans made to the
student or on behalf of the student for the payment period or period of enrollment for which a
return of funds is required. Those funds must be credited to outstanding balances for the payment
period or period of enrollment for which a return of funds is required in the following order: (i)
Unsubsidized Federal Direct Stafford loans, (ii) Subsidized Federal Direct Stafford loans, (iii) Federal
Direct PLUS received on behalf of the student. If unearned funds remain to be returned after
repayment of all outstanding loan amounts, the remaining excess must be credited to any amount
awarded for the payment period or period of enrollment for which a return of funds is required in
the following order: (i) Federal Pell Grants, (ii) Iraq and Afghanistan Service Grants, (iii) FSEOG
Program aid, (iv) TEACH Grants.
Statement of Condition: During the audit, it was noted that the University returned funds in an
incorrect sequence during the Return to Title IV Funds process upon student withdrawal.
Questioned Costs: There is no known monetary error as the mistake causes a misclassification in
type of award, but net award amount is not affected.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 2, indicating an error rate of 100%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the institution applied the percentage of
earned aid to each type of disbursed aid individually, returning the remaining portion of each type
of aid. However, the guidance stipulates that funds should be returned in a set order, returning the
full amount of each type before moving to the next.
In the return to Title IV process for the first student, the institution calculated an earned percentage
of 50.0% based upon completed days. The student had been disbursed both subsidized and
unsubsidized loans for the term. The director applied the 50.0% to each subsidized and unsubsidized
awards to determine the monetary amounts of earned aid, returning the remaining $495 of
subsidized and $866 unsubsidized loan disbursements to G5. The appropriate treatment would have
been to return the full unearned portion of aid from the unsubsidized award.
In the return to Title IV process for the second student, the institution calculated an earned
percentage of 42.2% based upon completed days. The student had been disbursed both Pell and
FSEOG for the term. The director applied the 42.2% to each Pell and FSEOG awards to determine the
monetary amounts of earned aid, returning the remaining $2,156 of Pell and $146 of FSEOG
disbursements to G5. The appropriate treatment would have been to return the full unearned
portion of aid from the Pell award.
Recommendation: The University should ensure that funds are returned in the prescribed sequence
in the determination of the return of aid as designated by the Compliance Supplement and the
Student Financial Aid Handbook.
View of Responsible Officials: The University’s Vice President of Finance and Financial Aid
Administrator recently attended a week-long workshop and received training to complete the R2T4
calculation via COD. The training was received after the infringements and a plan has been adapted
to utilize COD for future R2T4 calculations and sequence. The school calendar has been updated in
COD for correct future calculations and sequence.
2024-002 Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education,
William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding 2023-002)
Criteria: In accordance with 16 CFR 314.4, a University shall develop, implement, and maintain a
comprehensive information security program that is written in one or more readily accessible parts
and contains administrative, technical, and physical safeguards that are appropriate to your size and
complexity, the nature and scope of your activities, and the sensitivity of any customer information
at issue and must contain all of the elements that are further described in 16 CFR 314.4.
Statement of Condition: During the audit, it was noted that the University’s Gramm-Leach-Bliley Act
Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the
application of the comprehensive information security program was not effectively administered by
the University during the 2024 year. An updated policy was put into place in February 2024, which
addressed several of the deficiencies noted in the existing policy, but not all.
The seven required elements for the GLBA policy are as follows, along with the status within each of
the University’s policies in place during the year:
1. The policy designates a qualified individual responsible for overseeing and implementing the
institution’s information security program and enforcing the information security program in
compliance.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement, identifying a GLBA Compliance Program Coordinator responsible for
the listed functions.
2. The policy provides for the information security program to be based on a risk assessment that
identifies reasonably foreseeable internal and external risks to the security, confidentiality, and
integrity of customer information (as the term customer information applies to the institution)
that could result in the unauthorized disclosure, misuse, alteration, destruction, or other
compromise of such information, and assesses the sufficiency of any safeguards in place to
control these risks.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement.
3. The policy provides for the design and implementation of safeguards to control the risks the
institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the
institution’s written information security program must address the implementation of the
minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), which are detailed as follows:
3.1. Implement and periodically review access controls.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement, instituting a continuous monitoring process undertaken at
periodic intervals. The timeframe of the periodic intervals is not defined.
3.2. Conduct a periodic inventory of data, noting where it is collected, stored or transmitted.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement. They will utilize data mapping to complete this process.
However, the institution was unable to provide a date of the last inventory completed.
3.3. Encrypt customer information on the institution’s system and when it is in transit.
Both the existing policy and the newly implemented policy are silent on this requirement.
3.4. Assess applications developed by the institution.
Both the existing policy and the newly implemented policy are silent on this requirement.
3.5. Implement multi-factor authentication for anyone accessing customer information on the
institution’s system.
Both the existing policy and the newly implemented policy are silent on this requirement.
3.6. Dispose of customer information securely.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement. The new policy provides a link to the information regarding
retention and destruction of documents.
3.7. Anticipate and evaluate changes to the information system or network.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement.
3.8. Maintain a log of authorized users’ activity and keep an eye out for unauthorized access.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement. The policy provides a link to the acceptable use policy.
4. The policy provides for the institution to regularly test or otherwise monitor the effectiveness of
the safeguards it has implemented.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement, instituting a continuous monitoring process undertaken at periodic
intervals. The timeframe of the periodic intervals is not defined.
5. The policy provides for the implementation of policies and procedures to ensure that personnel
are able to enact the information security program.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement, identifying the IT department in collaboration with the VP of finance
as the responsible parties for this process.
6. The policy addresses how the institution will oversee its information system service providers.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement. The program coordinator has been tasked with this activity in
conjunction with the VP of Finance.
7. The policy provides for the evaluation and adjustment of its information security program in
light of the results of the required testing and monitoring; any material changes to its operations
or business arrangements; the results of the required risk assessments; or any other
circumstances that it knows or has reason to know may have a material impact the institution’s
information security program.
This attribute was not addressed in the existing policy; the newly implemented policy does
address this requirement. The policy will be reviewed annually at a minimum.
Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in
nature.
Perspective Information: The audit included testing of the University’s Gramm-Leach-Bliley Act
Policy as outlined in Part 5 of the Compliance Supplement including the application of this program
for the year.
Cause and Effect: Due to lapses of oversight in multiple departments, the University failed to update
their GLBA policy in a timely manner to include the required components in accordance with the
Compliance Supplement. The University implemented an updated policy in February 2024. Both the
previous policy and updated policy were subjected to audit procedures, and several requirements
were missing from both policies. Therefore, the policy is considered incomplete and does not
provide the appropriate disclosures to consumers.
Recommendation: The University should update their Gramm-Leach-Bliley Act Policy to be in
accordance with the requirements and put in place effective controls and practices to ensure the
policy is monitored in a way to ensure it is administered effectively.
View of Responsible Officials: The University recently reviewed the Gramm-Leach-Bliley Act Policy
and has put in place controls and practices to effectively monitor and administer the policy. In April
2024, we hired an IT company to help with various campus needs, including data compliance
procedures and security measures. The company has been reviewing our current policies and
making recommendations to implement appropriate safeguards to keep the university up to date
and compliant. We have already installed multi-factor authentication features for our software
systems, and there are more updates to come. In July 2024, we received a notice of compliance
from the Federal Student Aid regarding our corrective action procedures for the Gramm-Leach-Bliley
Act.
2024-003 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003 and 2023-004)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $20 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office continued with the calendar process showing days of attendance
from the first day of school to the last using the school’s master calendar as a reference. This will be
used also as a double check of days when calculating returns. The dates used in the return
calculations were off a day due to misreading the ending date of semester. The Financial Aid
Administrator verified the beginning and last day of each semester with the Registrar’s office in
writing.
2024-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2023-005)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $1,984 under-awarded. Extrapolation of the error
was not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University has enhanced the process of completing return to Title
IV calculations by incorporating additional training and workshops provided by the Department of
Education. The financial aid office has continued with the implementation of the calendar that
displays the attendance days from the first day of school to the last day of school, referring to the
school’s master calendar. The financial aid office added an extra verification step of written
notification from the Registrar’s office of beginning and end days for each semester. The return
calculations were one day off due to the misinterpretation of the semester’s ending date.
2024-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(i), unearned funds returned by the institution or the
student, as appropriate, must be credited to outstanding balances on Title IV loans made to the
student or on behalf of the student for the payment period or period of enrollment for which a
return of funds is required. Those funds must be credited to outstanding balances for the payment
period or period of enrollment for which a return of funds is required in the following order: (i)
Unsubsidized Federal Direct Stafford loans, (ii) Subsidized Federal Direct Stafford loans, (iii) Federal
Direct PLUS received on behalf of the student. If unearned funds remain to be returned after
repayment of all outstanding loan amounts, the remaining excess must be credited to any amount
awarded for the payment period or period of enrollment for which a return of funds is required in
the following order: (i) Federal Pell Grants, (ii) Iraq and Afghanistan Service Grants, (iii) FSEOG
Program aid, (iv) TEACH Grants.
Statement of Condition: During the audit, it was noted that the University returned funds in an
incorrect sequence during the Return to Title IV Funds process upon student withdrawal.
Questioned Costs: There is no known monetary error as the mistake causes a misclassification in
type of award, but net award amount is not affected.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 2, indicating an error rate of 100%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the institution applied the percentage of
earned aid to each type of disbursed aid individually, returning the remaining portion of each type
of aid. However, the guidance stipulates that funds should be returned in a set order, returning the
full amount of each type before moving to the next.
In the return to Title IV process for the first student, the institution calculated an earned percentage
of 50.0% based upon completed days. The student had been disbursed both subsidized and
unsubsidized loans for the term. The director applied the 50.0% to each subsidized and unsubsidized
awards to determine the monetary amounts of earned aid, returning the remaining $495 of
subsidized and $866 unsubsidized loan disbursements to G5. The appropriate treatment would have
been to return the full unearned portion of aid from the unsubsidized award.
In the return to Title IV process for the second student, the institution calculated an earned
percentage of 42.2% based upon completed days. The student had been disbursed both Pell and
FSEOG for the term. The director applied the 42.2% to each Pell and FSEOG awards to determine the
monetary amounts of earned aid, returning the remaining $2,156 of Pell and $146 of FSEOG
disbursements to G5. The appropriate treatment would have been to return the full unearned
portion of aid from the Pell award.
Recommendation: The University should ensure that funds are returned in the prescribed sequence
in the determination of the return of aid as designated by the Compliance Supplement and the
Student Financial Aid Handbook.
View of Responsible Officials: The University’s Vice President of Finance and Financial Aid
Administrator recently attended a week-long workshop and received training to complete the R2T4
calculation via COD. The training was received after the infringements and a plan has been adapted
to utilize COD for future R2T4 calculations and sequence. The school calendar has been updated in
COD for correct future calculations and sequence.