Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).
Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.
Condition: Campus Level: Certain students’ enrollment status changes were not reported or were reported outside of the required timeframe.
Program Level: Significant data elements were inaccurately reported for certain students.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 5 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days.
For 5 of 40 campus level records tested, the University did not notify the Department of a change in the student’s enrollment.
For 25 of 40 program level records tested, the University did not accurately report one or more significant data elements to NSLDS.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-002.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are reported accurately and timely to NSLDS.
Views of Responsible Officials: All instances of this finding occurred during the fall 2023 semester while we were still in the implementation process for joining the National Student Clearinghouse. Since completing implementation, there have been no further instances. See “Status of Finding” for Finding 2023-002.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).
Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.
Condition: Campus Level: Certain students’ enrollment status changes were not reported or were reported outside of the required timeframe.
Program Level: Significant data elements were inaccurately reported for certain students.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 5 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days.
For 5 of 40 campus level records tested, the University did not notify the Department of a change in the student’s enrollment.
For 25 of 40 program level records tested, the University did not accurately report one or more significant data elements to NSLDS.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-002.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are reported accurately and timely to NSLDS.
Views of Responsible Officials: All instances of this finding occurred during the fall 2023 semester while we were still in the implementation process for joining the National Student Clearinghouse. Since completing implementation, there have been no further instances. See “Status of Finding” for Finding 2023-002.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Pell Grant Program (ALN 84.063), Federal Direct Loan Program (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E).
Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified.
Cause: Administrative oversight and insufficient internal controls over verification requirements.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 8 of 15 students tested, the University did not complete appropriate verification procedures prior to disbursing aid.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that students are verified as required.
Views of Responsible Officials: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process.
3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign.
3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal.
2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Pell Grant Program (ALN 84.063), Federal Direct Loan Program (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E).
Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified.
Cause: Administrative oversight and insufficient internal controls over verification requirements.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 8 of 15 students tested, the University did not complete appropriate verification procedures prior to disbursing aid.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that students are verified as required.
Views of Responsible Officials: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process.
3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign.
3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal.
2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Pell Grant Program (ALN 84.063), Federal Direct Loan Program (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E).
Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified.
Cause: Administrative oversight and insufficient internal controls over verification requirements.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 8 of 15 students tested, the University did not complete appropriate verification procedures prior to disbursing aid.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that students are verified as required.
Views of Responsible Officials: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process.
3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign.
3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal.
2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Pell Grant Program (ALN 84.063), Federal Direct Loan Program (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E).
Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified.
Cause: Administrative oversight and insufficient internal controls over verification requirements.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 8 of 15 students tested, the University did not complete appropriate verification procedures prior to disbursing aid.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that students are verified as required.
Views of Responsible Officials: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process.
3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign.
3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal.
2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members.
Federal Program Information: Federal Direct Loan Program (ALN 84.268)
Criteria or Specific Requirement: According to 34 CFR 685.303, except in the case of a late disbursement under 685.303(f) or as provided in paragraph (b)(3)(iii) of § 685.303, a school may disburse loan proceeds only to a student, or a parent in the case of a Direct PLUS Loan obtained by a parent borrower, if the school determines the student has continuously maintained eligibility in accordance with the provisions of § 685.200 from the beginning of the loan period for which the loan was intended.
Condition: The University disbursed loan funds to a student who failed to make satisfactory academic progress at the end of his probationary period.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: Overpayment of Title IV funds.
Questioned Costs: Below reporting threshold.
Context: For 1 of 40 students tested, the University did not appropriately assess the student’s eligibility prior to disbursing loan funds.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure proper determination of continuous eligibility.
Views of Responsible Officials: An incorrect satisfactory academic progress tracking status was assigned to a single student, which resulted in the one student receiving federal aid for the spring semester when they should have been marked as ineligible. The spring disbursement was corrected promptly when uncovered and funds have been returned to ED. An enhanced system is now in place to more clearly track the satisfactory academic progress of students who take a leave of absence from the university and return without demonstrating satisfactory academic progress at a different school.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN 84.007)
Criteria or Specific Requirement: C. Cash Management: Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the ED (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition: An instance during the year was identified where funds drawn in excess of amounts disbursed were held longer than the allowable timeframe.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with cash management requirements.
Questioned Costs: None.
Context: 1 instance of cash held in excess of the allowable timeframe for the Federal Supplement Educational Opportunity Grants Program.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its procedures to ensure excess cash balances are eliminated timely.
Views of Responsible Officials: Corrective action steps have been taken to ensure that excess cash balances are eliminated in a timely manner. The corrective action focuses on the campus-based awards, as there was only one instance of non-compliance for the FSEOG, and adds an additional step between financial aid and the finance office to verify the amount of funds disbursed to students before initiating a drawdown of funds.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).
Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.
Condition: Campus Level: Certain students’ enrollment status changes were not reported or were reported outside of the required timeframe.
Program Level: Significant data elements were inaccurately reported for certain students.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 5 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days.
For 5 of 40 campus level records tested, the University did not notify the Department of a change in the student’s enrollment.
For 25 of 40 program level records tested, the University did not accurately report one or more significant data elements to NSLDS.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-002.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are reported accurately and timely to NSLDS.
Views of Responsible Officials: All instances of this finding occurred during the fall 2023 semester while we were still in the implementation process for joining the National Student Clearinghouse. Since completing implementation, there have been no further instances. See “Status of Finding” for Finding 2023-002.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).
Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.
Condition: Campus Level: Certain students’ enrollment status changes were not reported or were reported outside of the required timeframe.
Program Level: Significant data elements were inaccurately reported for certain students.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 5 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days.
For 5 of 40 campus level records tested, the University did not notify the Department of a change in the student’s enrollment.
For 25 of 40 program level records tested, the University did not accurately report one or more significant data elements to NSLDS.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-002.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are reported accurately and timely to NSLDS.
Views of Responsible Officials: All instances of this finding occurred during the fall 2023 semester while we were still in the implementation process for joining the National Student Clearinghouse. Since completing implementation, there have been no further instances. See “Status of Finding” for Finding 2023-002.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Pell Grant Program (ALN 84.063), Federal Direct Loan Program (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E).
Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified.
Cause: Administrative oversight and insufficient internal controls over verification requirements.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 8 of 15 students tested, the University did not complete appropriate verification procedures prior to disbursing aid.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that students are verified as required.
Views of Responsible Officials: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process.
3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign.
3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal.
2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Pell Grant Program (ALN 84.063), Federal Direct Loan Program (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E).
Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified.
Cause: Administrative oversight and insufficient internal controls over verification requirements.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 8 of 15 students tested, the University did not complete appropriate verification procedures prior to disbursing aid.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that students are verified as required.
Views of Responsible Officials: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process.
3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign.
3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal.
2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Pell Grant Program (ALN 84.063), Federal Direct Loan Program (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E).
Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified.
Cause: Administrative oversight and insufficient internal controls over verification requirements.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 8 of 15 students tested, the University did not complete appropriate verification procedures prior to disbursing aid.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that students are verified as required.
Views of Responsible Officials: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process.
3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign.
3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal.
2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Pell Grant Program (ALN 84.063), Federal Direct Loan Program (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E).
Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified.
Cause: Administrative oversight and insufficient internal controls over verification requirements.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 8 of 15 students tested, the University did not complete appropriate verification procedures prior to disbursing aid.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that students are verified as required.
Views of Responsible Officials: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process.
3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign.
3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal.
2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members.
Federal Program Information: Federal Direct Loan Program (ALN 84.268)
Criteria or Specific Requirement: According to 34 CFR 685.303, except in the case of a late disbursement under 685.303(f) or as provided in paragraph (b)(3)(iii) of § 685.303, a school may disburse loan proceeds only to a student, or a parent in the case of a Direct PLUS Loan obtained by a parent borrower, if the school determines the student has continuously maintained eligibility in accordance with the provisions of § 685.200 from the beginning of the loan period for which the loan was intended.
Condition: The University disbursed loan funds to a student who failed to make satisfactory academic progress at the end of his probationary period.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: Overpayment of Title IV funds.
Questioned Costs: Below reporting threshold.
Context: For 1 of 40 students tested, the University did not appropriately assess the student’s eligibility prior to disbursing loan funds.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its internal controls over compliance to ensure proper determination of continuous eligibility.
Views of Responsible Officials: An incorrect satisfactory academic progress tracking status was assigned to a single student, which resulted in the one student receiving federal aid for the spring semester when they should have been marked as ineligible. The spring disbursement was corrected promptly when uncovered and funds have been returned to ED. An enhanced system is now in place to more clearly track the satisfactory academic progress of students who take a leave of absence from the university and return without demonstrating satisfactory academic progress at a different school.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN 84.007)
Criteria or Specific Requirement: C. Cash Management: Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the ED (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition: An instance during the year was identified where funds drawn in excess of amounts disbursed were held longer than the allowable timeframe.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with cash management requirements.
Questioned Costs: None.
Context: 1 instance of cash held in excess of the allowable timeframe for the Federal Supplement Educational Opportunity Grants Program.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its procedures to ensure excess cash balances are eliminated timely.
Views of Responsible Officials: Corrective action steps have been taken to ensure that excess cash balances are eliminated in a timely manner. The corrective action focuses on the campus-based awards, as there was only one instance of non-compliance for the FSEOG, and adds an additional step between financial aid and the finance office to verify the amount of funds disbursed to students before initiating a drawdown of funds.