Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203 specifies the annual and aggregate loan limits the Institutions may not exceed for an academic year of study under the Direct Loan program and also requires loans to be prorated for a program of student that is less than a full academic year in length. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements..
Condition: During our testing, we noted two students who were awarded incorrect amounts for Subsidized and Unsubsidized Direct Loans.
Questioned costs: $1,247
Context: During our testing of forty students, we noted one student was over awarded unsubsidized loans, and a second student was under awarded subsidized loans and over awarded unsubsidized loans.
Cause: One student was awarded to an incorrect cost of attendance. A second student was awarded a maximum unsubsidized loan and remaining subsidized loan up to their remaining need.
Effect: The University paid one student an amount of loans that was greater than the student was eligible to receive and paid one student an amount of loans that was less than the student was eligible to receive.
Repeat Finding: Yes, 2023-001
Recommendation: We recommend that the University review their awarding procedures and implement procedures to ensure direct loans are awarded within student eligibility.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred.
Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred.
Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred.
Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred.
Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred.
Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: Section 479A of the higher education administration (HEA) gives an institution’s financial aid administrators (FAA) the authority to use professional judgment to adjust, on a case-by-case basis, the cost of attendance or the values of the items used in calculating the expected family contribution (EFC) to reflect a student’s special circumstances. In making case-by-case determinations, the FAA must obtain and retain in the affected student’s file documents supporting and substantiating the reasons for any adjustment. The HEA does not provide a framework for the FAA to calculate the expected student or parent contribution or for the adjusted aid amounts. In addition, the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that there was no documentation of review of professional judgement issued available.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty had professional judgement issued. We were able to review the documents, however we were unable to see evidence that a review of the professional judgement issuance had been performed by the University.
Cause: There was no documentation to show that procedures to review professional judgement decisions were completed.
Effect: Failure to assess professional judgement decisions could result in an employee not adequately assessing the students’ needs and leave students underserved. Failure to review verification documents could result in students’ verification not being completed correctly.
Repeat Finding: No.
Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: Section 479A of the higher education administration (HEA) gives an institution’s financial aid administrators (FAA) the authority to use professional judgment to adjust, on a case-by-case basis, the cost of attendance or the values of the items used in calculating the expected family contribution (EFC) to reflect a student’s special circumstances. In making case-by-case determinations, the FAA must obtain and retain in the affected student’s file documents supporting and substantiating the reasons for any adjustment. The HEA does not provide a framework for the FAA to calculate the expected student or parent contribution or for the adjusted aid amounts. In addition, the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that there was no documentation of review of professional judgement issued available.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty had professional judgement issued. We were able to review the documents, however we were unable to see evidence that a review of the professional judgement issuance had been performed by the University.
Cause: There was no documentation to show that procedures to review professional judgement decisions were completed.
Effect: Failure to assess professional judgement decisions could result in an employee not adequately assessing the students’ needs and leave students underserved. Failure to review verification documents could result in students’ verification not being completed correctly.
Repeat Finding: No.
Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: Section 479A of the higher education administration (HEA) gives an institution’s financial aid administrators (FAA) the authority to use professional judgment to adjust, on a case-by-case basis, the cost of attendance or the values of the items used in calculating the expected family contribution (EFC) to reflect a student’s special circumstances. In making case-by-case determinations, the FAA must obtain and retain in the affected student’s file documents supporting and substantiating the reasons for any adjustment. The HEA does not provide a framework for the FAA to calculate the expected student or parent contribution or for the adjusted aid amounts. In addition, the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that there was no documentation of review of professional judgement issued available.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty had professional judgement issued. We were able to review the documents, however we were unable to see evidence that a review of the professional judgement issuance had been performed by the University.
Cause: There was no documentation to show that procedures to review professional judgement decisions were completed.
Effect: Failure to assess professional judgement decisions could result in an employee not adequately assessing the students’ needs and leave students underserved. Failure to review verification documents could result in students’ verification not being completed correctly.
Repeat Finding: No.
Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: Section 479A of the higher education administration (HEA) gives an institution’s financial aid administrators (FAA) the authority to use professional judgment to adjust, on a case-by-case basis, the cost of attendance or the values of the items used in calculating the expected family contribution (EFC) to reflect a student’s special circumstances. In making case-by-case determinations, the FAA must obtain and retain in the affected student’s file documents supporting and substantiating the reasons for any adjustment. The HEA does not provide a framework for the FAA to calculate the expected student or parent contribution or for the adjusted aid amounts. In addition, the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that there was no documentation of review of professional judgement issued available.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty had professional judgement issued. We were able to review the documents, however we were unable to see evidence that a review of the professional judgement issuance had been performed by the University.
Cause: There was no documentation to show that procedures to review professional judgement decisions were completed.
Effect: Failure to assess professional judgement decisions could result in an employee not adequately assessing the students’ needs and leave students underserved. Failure to review verification documents could result in students’ verification not being completed correctly.
Repeat Finding: No.
Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: Section 479A of the higher education administration (HEA) gives an institution’s financial aid administrators (FAA) the authority to use professional judgment to adjust, on a case-by-case basis, the cost of attendance or the values of the items used in calculating the expected family contribution (EFC) to reflect a student’s special circumstances. In making case-by-case determinations, the FAA must obtain and retain in the affected student’s file documents supporting and substantiating the reasons for any adjustment. The HEA does not provide a framework for the FAA to calculate the expected student or parent contribution or for the adjusted aid amounts. In addition, the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that there was no documentation of review of professional judgement issued available.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty had professional judgement issued. We were able to review the documents, however we were unable to see evidence that a review of the professional judgement issuance had been performed by the University.
Cause: There was no documentation to show that procedures to review professional judgement decisions were completed.
Effect: Failure to assess professional judgement decisions could result in an employee not adequately assessing the students’ needs and leave students underserved. Failure to review verification documents could result in students’ verification not being completed correctly.
Repeat Finding: No.
Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred.
Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available.
Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred.
Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available.
Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred.
Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available.
Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred.
Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available.
Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred.
Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available.
Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: A Direct Subsidized Loan, Direct Unsubsidized Loan, or student Direct PLUS Loan borrower who is graduating, leaving school, or dropping below half-time enrollment is required to complete exit counseling. If the student drops out without notifying the school, the school must confirm that the student has completed online counseling or mail exit counseling material to the student at their last known address. The school may also email the information to the student’s home (not school) email address if the school has it. The school may also send the student a direct link to the exit counseling materials online. Whatever method the school chooses must be used within 30 days of learning that the borrower has withdrawn or failed to participate in an exit counseling session. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted the University did not send notifications of exit counseling to students who graduated or withdrew during the year.
Questioned costs: None reported.
Context: During our testing of 40 students, we noted exit counseling notifications were not sent out to students during fiscal year 2024.
Cause: The University does not have a process in place.
Effect: Failure to send exit counseling notifications could result in a student not completing their exit counseling.
Repeat Finding: No.
Recommendation: We recommend the University implement procedures to ensure exit counseling notifications are sent to students who graduated or withdrew.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203 specifies the annual and aggregate loan limits the Institutions may not exceed for an academic year of study under the Direct Loan program and also requires loans to be prorated for a program of student that is less than a full academic year in length. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements..
Condition: During our testing, we noted two students who were awarded incorrect amounts for Subsidized and Unsubsidized Direct Loans.
Questioned costs: $1,247
Context: During our testing of forty students, we noted one student was over awarded unsubsidized loans, and a second student was under awarded subsidized loans and over awarded unsubsidized loans.
Cause: One student was awarded to an incorrect cost of attendance. A second student was awarded a maximum unsubsidized loan and remaining subsidized loan up to their remaining need.
Effect: The University paid one student an amount of loans that was greater than the student was eligible to receive and paid one student an amount of loans that was less than the student was eligible to receive.
Repeat Finding: Yes, 2023-001
Recommendation: We recommend that the University review their awarding procedures and implement procedures to ensure direct loans are awarded within student eligibility.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred.
Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred.
Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred.
Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred.
Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred.
Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: Section 479A of the higher education administration (HEA) gives an institution’s financial aid administrators (FAA) the authority to use professional judgment to adjust, on a case-by-case basis, the cost of attendance or the values of the items used in calculating the expected family contribution (EFC) to reflect a student’s special circumstances. In making case-by-case determinations, the FAA must obtain and retain in the affected student’s file documents supporting and substantiating the reasons for any adjustment. The HEA does not provide a framework for the FAA to calculate the expected student or parent contribution or for the adjusted aid amounts. In addition, the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that there was no documentation of review of professional judgement issued available.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty had professional judgement issued. We were able to review the documents, however we were unable to see evidence that a review of the professional judgement issuance had been performed by the University.
Cause: There was no documentation to show that procedures to review professional judgement decisions were completed.
Effect: Failure to assess professional judgement decisions could result in an employee not adequately assessing the students’ needs and leave students underserved. Failure to review verification documents could result in students’ verification not being completed correctly.
Repeat Finding: No.
Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: Section 479A of the higher education administration (HEA) gives an institution’s financial aid administrators (FAA) the authority to use professional judgment to adjust, on a case-by-case basis, the cost of attendance or the values of the items used in calculating the expected family contribution (EFC) to reflect a student’s special circumstances. In making case-by-case determinations, the FAA must obtain and retain in the affected student’s file documents supporting and substantiating the reasons for any adjustment. The HEA does not provide a framework for the FAA to calculate the expected student or parent contribution or for the adjusted aid amounts. In addition, the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that there was no documentation of review of professional judgement issued available.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty had professional judgement issued. We were able to review the documents, however we were unable to see evidence that a review of the professional judgement issuance had been performed by the University.
Cause: There was no documentation to show that procedures to review professional judgement decisions were completed.
Effect: Failure to assess professional judgement decisions could result in an employee not adequately assessing the students’ needs and leave students underserved. Failure to review verification documents could result in students’ verification not being completed correctly.
Repeat Finding: No.
Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: Section 479A of the higher education administration (HEA) gives an institution’s financial aid administrators (FAA) the authority to use professional judgment to adjust, on a case-by-case basis, the cost of attendance or the values of the items used in calculating the expected family contribution (EFC) to reflect a student’s special circumstances. In making case-by-case determinations, the FAA must obtain and retain in the affected student’s file documents supporting and substantiating the reasons for any adjustment. The HEA does not provide a framework for the FAA to calculate the expected student or parent contribution or for the adjusted aid amounts. In addition, the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that there was no documentation of review of professional judgement issued available.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty had professional judgement issued. We were able to review the documents, however we were unable to see evidence that a review of the professional judgement issuance had been performed by the University.
Cause: There was no documentation to show that procedures to review professional judgement decisions were completed.
Effect: Failure to assess professional judgement decisions could result in an employee not adequately assessing the students’ needs and leave students underserved. Failure to review verification documents could result in students’ verification not being completed correctly.
Repeat Finding: No.
Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: Section 479A of the higher education administration (HEA) gives an institution’s financial aid administrators (FAA) the authority to use professional judgment to adjust, on a case-by-case basis, the cost of attendance or the values of the items used in calculating the expected family contribution (EFC) to reflect a student’s special circumstances. In making case-by-case determinations, the FAA must obtain and retain in the affected student’s file documents supporting and substantiating the reasons for any adjustment. The HEA does not provide a framework for the FAA to calculate the expected student or parent contribution or for the adjusted aid amounts. In addition, the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that there was no documentation of review of professional judgement issued available.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty had professional judgement issued. We were able to review the documents, however we were unable to see evidence that a review of the professional judgement issuance had been performed by the University.
Cause: There was no documentation to show that procedures to review professional judgement decisions were completed.
Effect: Failure to assess professional judgement decisions could result in an employee not adequately assessing the students’ needs and leave students underserved. Failure to review verification documents could result in students’ verification not being completed correctly.
Repeat Finding: No.
Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: Section 479A of the higher education administration (HEA) gives an institution’s financial aid administrators (FAA) the authority to use professional judgment to adjust, on a case-by-case basis, the cost of attendance or the values of the items used in calculating the expected family contribution (EFC) to reflect a student’s special circumstances. In making case-by-case determinations, the FAA must obtain and retain in the affected student’s file documents supporting and substantiating the reasons for any adjustment. The HEA does not provide a framework for the FAA to calculate the expected student or parent contribution or for the adjusted aid amounts. In addition, the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that there was no documentation of review of professional judgement issued available.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty had professional judgement issued. We were able to review the documents, however we were unable to see evidence that a review of the professional judgement issuance had been performed by the University.
Cause: There was no documentation to show that procedures to review professional judgement decisions were completed.
Effect: Failure to assess professional judgement decisions could result in an employee not adequately assessing the students’ needs and leave students underserved. Failure to review verification documents could result in students’ verification not being completed correctly.
Repeat Finding: No.
Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred.
Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available.
Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred.
Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available.
Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred.
Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available.
Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred.
Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available.
Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred.
Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available.
Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: A Direct Subsidized Loan, Direct Unsubsidized Loan, or student Direct PLUS Loan borrower who is graduating, leaving school, or dropping below half-time enrollment is required to complete exit counseling. If the student drops out without notifying the school, the school must confirm that the student has completed online counseling or mail exit counseling material to the student at their last known address. The school may also email the information to the student’s home (not school) email address if the school has it. The school may also send the student a direct link to the exit counseling materials online. Whatever method the school chooses must be used within 30 days of learning that the borrower has withdrawn or failed to participate in an exit counseling session. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted the University did not send notifications of exit counseling to students who graduated or withdrew during the year.
Questioned costs: None reported.
Context: During our testing of 40 students, we noted exit counseling notifications were not sent out to students during fiscal year 2024.
Cause: The University does not have a process in place.
Effect: Failure to send exit counseling notifications could result in a student not completing their exit counseling.
Repeat Finding: No.
Recommendation: We recommend the University implement procedures to ensure exit counseling notifications are sent to students who graduated or withdrew.
View of Responsible Official: The University agrees with the finding.