Audit 331081

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 – Federal Direct Loan Program Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 (b) outlines that schools must update the secretary with pertinent information within 30 days (unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days) after the date the school discovers a student changed enrollment from half time/full time/graduate/withdrawal/etc. Section 4.4.2 of the NSLDS Enrollment Reporting Guide (Circa November 2018) establishes the definition of the effective date, certification date, and received date. Condition: During our detail testing of NSLDS Enrollment Reporting we noted instances where the University did not comply with the requirements noted above. Questioned costs: None. Context: During our detail testing of NSLDS Enrollment Reporting we noted the following discrepancies in our sample of 30 students:  11 instances in which the program enrollment effective date did not match the program-level enrollment effective date per NSLDS  6 instances where the student status change was not reported within the required time frame Cause: the University’s policies and procedures did not detect and correct these errors to ensure compliance. Effect: Noncompliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: Yes, prior year finding 2023-002. Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Views of responsible officials: See Corrective Action Plan prepared by the University.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 – Federal Direct Student Loans, 84.063 – Pell Grant Program Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: As defined in 34 CFR 668.164(a), the disbursement date is the date that a school credits a student’s account at the school or pays a student or parent borrower directly with Title IV funds received from the U.S. Department of Education (the Department) or with institutional funds in advance of receiving Title IV program funds. This is the date that a school must report to the COD System as the actual disbursement date for a Direct Loan, as distinguished from the anticipated disbursement date. Condition: During our testing we noted instances where the wrong disbursement date was reported to COD. Questioned costs: None Context: Of the 60 disbursements tested, we noted 9 instances where the wrong disbursement date was reported. Cause: University’s policies and procedures did not ensure compliance. Effect: Noncompliance with the reporting requirements. Repeat Finding: Yes, prior year finding 2023-005. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 – Federal Direct Loan Program Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 (b) outlines that schools must update the secretary with pertinent information within 30 days (unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days) after the date the school discovers a student changed enrollment from half time/full time/graduate/withdrawal/etc. Section 4.4.2 of the NSLDS Enrollment Reporting Guide (Circa November 2018) establishes the definition of the effective date, certification date, and received date. Condition: During our detail testing of NSLDS Enrollment Reporting we noted instances where the University did not comply with the requirements noted above. Questioned costs: None. Context: During our detail testing of NSLDS Enrollment Reporting we noted the following discrepancies in our sample of 30 students:  11 instances in which the program enrollment effective date did not match the program-level enrollment effective date per NSLDS  6 instances where the student status change was not reported within the required time frame Cause: the University’s policies and procedures did not detect and correct these errors to ensure compliance. Effect: Noncompliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: Yes, prior year finding 2023-002. Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Views of responsible officials: See Corrective Action Plan prepared by the University.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 – Federal Direct Student Loans, 84.063 – Pell Grant Program Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: As defined in 34 CFR 668.164(a), the disbursement date is the date that a school credits a student’s account at the school or pays a student or parent borrower directly with Title IV funds received from the U.S. Department of Education (the Department) or with institutional funds in advance of receiving Title IV program funds. This is the date that a school must report to the COD System as the actual disbursement date for a Direct Loan, as distinguished from the anticipated disbursement date. Condition: During our testing we noted instances where the wrong disbursement date was reported to COD. Questioned costs: None Context: Of the 60 disbursements tested, we noted 9 instances where the wrong disbursement date was reported. Cause: University’s policies and procedures did not ensure compliance. Effect: Noncompliance with the reporting requirements. Repeat Finding: Yes, prior year finding 2023-005. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.