FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds – Significant
Deficiency in Internal Controls Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria: The regulations 34 CFR 668.22 notes when a recipient of Title IV grant or loan funds withdraws
from a school after beginning attendance, the University must perform an R2T4 calculation to determine
the amount of Title IV aid earned by the student. If the amount disbursed to the student is greater than the
amount the student earned, the unearned funds must be returned. Additionally, there are specified
communications required to be given to the student by the school per 34 CFR 668.22(3)(a).
Condition/context: We selected a sample of 22 students out of a population of 168 that were identified
by the University as having received some federal assistance and withdrew from the University during the
year under audit. We believe this to be a representative sample of the population. We found one student
had dropped all Spring 2024 courses during the beginning of the term but an R2T4 calculation was not
performed when the University determined the withdraw on January 12, 2024. As there was no R2T4
calculation performed in January 2024, the University did not communicate timely to the student or return
funds within the required time period. The University communicated to the student five months later to
begin the return process.
Questioned costs: No questioned costs were identified as part of this finding.
Cause: The R2T4 calculation was not completed within 30 days of the date of withdraw due to ineffective
and incorrect tracking of the student’s courseload changes. Effect: The lack of an R2T4 calculation being performed when the University became aware of the student’s withdraw caused delay in returning federal funds and required communications to the student.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend the University ensure controls in place are followed and monitored to
ensure R2T4 calculations are performed and reviewed timely.
Views of responsible officials: Management agrees with the finding. A corrective action plan has been
created by management and is included in the following section.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds – Significant
Deficiency in Internal Controls Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria: The regulations 34 CFR 668.22 notes when a recipient of Title IV grant or loan funds withdraws
from a school after beginning attendance, the University must perform an R2T4 calculation to determine
the amount of Title IV aid earned by the student. If the amount disbursed to the student is greater than the
amount the student earned, the unearned funds must be returned. Additionally, there are specified
communications required to be given to the student by the school per 34 CFR 668.22(3)(a).
Condition/context: We selected a sample of 22 students out of a population of 168 that were identified
by the University as having received some federal assistance and withdrew from the University during the
year under audit. We believe this to be a representative sample of the population. We found one student
had dropped all Spring 2024 courses during the beginning of the term but an R2T4 calculation was not
performed when the University determined the withdraw on January 12, 2024. As there was no R2T4
calculation performed in January 2024, the University did not communicate timely to the student or return
funds within the required time period. The University communicated to the student five months later to
begin the return process.
Questioned costs: No questioned costs were identified as part of this finding.
Cause: The R2T4 calculation was not completed within 30 days of the date of withdraw due to ineffective
and incorrect tracking of the student’s courseload changes. Effect: The lack of an R2T4 calculation being performed when the University became aware of the student’s withdraw caused delay in returning federal funds and required communications to the student.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend the University ensure controls in place are followed and monitored to
ensure R2T4 calculations are performed and reviewed timely.
Views of responsible officials: Management agrees with the finding. A corrective action plan has been
created by management and is included in the following section.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds – Significant
Deficiency in Internal Controls Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria: The regulations 34 CFR 668.22 notes when a recipient of Title IV grant or loan funds withdraws
from a school after beginning attendance, the University must perform an R2T4 calculation to determine
the amount of Title IV aid earned by the student. If the amount disbursed to the student is greater than the
amount the student earned, the unearned funds must be returned. Additionally, there are specified
communications required to be given to the student by the school per 34 CFR 668.22(3)(a).
Condition/context: We selected a sample of 22 students out of a population of 168 that were identified
by the University as having received some federal assistance and withdrew from the University during the
year under audit. We believe this to be a representative sample of the population. We found one student
had dropped all Spring 2024 courses during the beginning of the term but an R2T4 calculation was not
performed when the University determined the withdraw on January 12, 2024. As there was no R2T4
calculation performed in January 2024, the University did not communicate timely to the student or return
funds within the required time period. The University communicated to the student five months later to
begin the return process.
Questioned costs: No questioned costs were identified as part of this finding.
Cause: The R2T4 calculation was not completed within 30 days of the date of withdraw due to ineffective
and incorrect tracking of the student’s courseload changes. Effect: The lack of an R2T4 calculation being performed when the University became aware of the student’s withdraw caused delay in returning federal funds and required communications to the student.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend the University ensure controls in place are followed and monitored to
ensure R2T4 calculations are performed and reviewed timely.
Views of responsible officials: Management agrees with the finding. A corrective action plan has been
created by management and is included in the following section.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds – Significant
Deficiency in Internal Controls Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria: The regulations 34 CFR 668.22 notes when a recipient of Title IV grant or loan funds withdraws
from a school after beginning attendance, the University must perform an R2T4 calculation to determine
the amount of Title IV aid earned by the student. If the amount disbursed to the student is greater than the
amount the student earned, the unearned funds must be returned. Additionally, there are specified
communications required to be given to the student by the school per 34 CFR 668.22(3)(a).
Condition/context: We selected a sample of 22 students out of a population of 168 that were identified
by the University as having received some federal assistance and withdrew from the University during the
year under audit. We believe this to be a representative sample of the population. We found one student
had dropped all Spring 2024 courses during the beginning of the term but an R2T4 calculation was not
performed when the University determined the withdraw on January 12, 2024. As there was no R2T4
calculation performed in January 2024, the University did not communicate timely to the student or return
funds within the required time period. The University communicated to the student five months later to
begin the return process.
Questioned costs: No questioned costs were identified as part of this finding.
Cause: The R2T4 calculation was not completed within 30 days of the date of withdraw due to ineffective
and incorrect tracking of the student’s courseload changes. Effect: The lack of an R2T4 calculation being performed when the University became aware of the student’s withdraw caused delay in returning federal funds and required communications to the student.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend the University ensure controls in place are followed and monitored to
ensure R2T4 calculations are performed and reviewed timely.
Views of responsible officials: Management agrees with the finding. A corrective action plan has been
created by management and is included in the following section.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds – Significant
Deficiency in Internal Controls Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria: The regulations 34 CFR 668.22 notes when a recipient of Title IV grant or loan funds withdraws
from a school after beginning attendance, the University must perform an R2T4 calculation to determine
the amount of Title IV aid earned by the student. If the amount disbursed to the student is greater than the
amount the student earned, the unearned funds must be returned. Additionally, there are specified
communications required to be given to the student by the school per 34 CFR 668.22(3)(a).
Condition/context: We selected a sample of 22 students out of a population of 168 that were identified
by the University as having received some federal assistance and withdrew from the University during the
year under audit. We believe this to be a representative sample of the population. We found one student
had dropped all Spring 2024 courses during the beginning of the term but an R2T4 calculation was not
performed when the University determined the withdraw on January 12, 2024. As there was no R2T4
calculation performed in January 2024, the University did not communicate timely to the student or return
funds within the required time period. The University communicated to the student five months later to
begin the return process.
Questioned costs: No questioned costs were identified as part of this finding.
Cause: The R2T4 calculation was not completed within 30 days of the date of withdraw due to ineffective
and incorrect tracking of the student’s courseload changes. Effect: The lack of an R2T4 calculation being performed when the University became aware of the student’s withdraw caused delay in returning federal funds and required communications to the student.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend the University ensure controls in place are followed and monitored to
ensure R2T4 calculations are performed and reviewed timely.
Views of responsible officials: Management agrees with the finding. A corrective action plan has been
created by management and is included in the following section.
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency
in Internal Control Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED’s) centralized database for students’ enrollment information. It is the University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes.
34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the
Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the
school discovers that:
1. A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
2. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – From a system generated population of 658 students who received federal aid
and either graduated, withdrew, changed their permanent address, or dropped during the year ended June 30, 2024, we selected a sample of 60 students. We believe this to be a representative sample of the population. The enrollment information and withdrawal or graduation date per the University’s records were compared to the information reported to NSLDS in order to determine if status changes were reported accurately and within the required timeframes.
Of the 60 students who graduated, had an address change, or withdrew, one was not reported to the NSLDS within the required timeframe and had an incorrect status reported to the NSLDS.
Questioned costs: No questioned costs were identified as part of this finding.
Cause – The University’s controls did not capture student status change timely. Effect – The NSLDS database did not include all accurate information in the timeframe required by ED. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine inschool status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans.
Repeat finding – This is not a repeat finding.
Recommendation: We recommend the University develop additional procedures to monitor the accuracy of information reported to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to correct information directly within NSLDS at any time.
Views of responsible officials: Management agrees with the finding. A corrective action plan has been
created by management and is included in the following section.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds – Significant
Deficiency in Internal Controls Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria: The regulations 34 CFR 668.22 notes when a recipient of Title IV grant or loan funds withdraws
from a school after beginning attendance, the University must perform an R2T4 calculation to determine
the amount of Title IV aid earned by the student. If the amount disbursed to the student is greater than the
amount the student earned, the unearned funds must be returned. Additionally, there are specified
communications required to be given to the student by the school per 34 CFR 668.22(3)(a).
Condition/context: We selected a sample of 22 students out of a population of 168 that were identified
by the University as having received some federal assistance and withdrew from the University during the
year under audit. We believe this to be a representative sample of the population. We found one student
had dropped all Spring 2024 courses during the beginning of the term but an R2T4 calculation was not
performed when the University determined the withdraw on January 12, 2024. As there was no R2T4
calculation performed in January 2024, the University did not communicate timely to the student or return
funds within the required time period. The University communicated to the student five months later to
begin the return process.
Questioned costs: No questioned costs were identified as part of this finding.
Cause: The R2T4 calculation was not completed within 30 days of the date of withdraw due to ineffective
and incorrect tracking of the student’s courseload changes. Effect: The lack of an R2T4 calculation being performed when the University became aware of the student’s withdraw caused delay in returning federal funds and required communications to the student.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend the University ensure controls in place are followed and monitored to
ensure R2T4 calculations are performed and reviewed timely.
Views of responsible officials: Management agrees with the finding. A corrective action plan has been
created by management and is included in the following section.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds – Significant
Deficiency in Internal Controls Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria: The regulations 34 CFR 668.22 notes when a recipient of Title IV grant or loan funds withdraws
from a school after beginning attendance, the University must perform an R2T4 calculation to determine
the amount of Title IV aid earned by the student. If the amount disbursed to the student is greater than the
amount the student earned, the unearned funds must be returned. Additionally, there are specified
communications required to be given to the student by the school per 34 CFR 668.22(3)(a).
Condition/context: We selected a sample of 22 students out of a population of 168 that were identified
by the University as having received some federal assistance and withdrew from the University during the
year under audit. We believe this to be a representative sample of the population. We found one student
had dropped all Spring 2024 courses during the beginning of the term but an R2T4 calculation was not
performed when the University determined the withdraw on January 12, 2024. As there was no R2T4
calculation performed in January 2024, the University did not communicate timely to the student or return
funds within the required time period. The University communicated to the student five months later to
begin the return process.
Questioned costs: No questioned costs were identified as part of this finding.
Cause: The R2T4 calculation was not completed within 30 days of the date of withdraw due to ineffective
and incorrect tracking of the student’s courseload changes. Effect: The lack of an R2T4 calculation being performed when the University became aware of the student’s withdraw caused delay in returning federal funds and required communications to the student.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend the University ensure controls in place are followed and monitored to
ensure R2T4 calculations are performed and reviewed timely.
Views of responsible officials: Management agrees with the finding. A corrective action plan has been
created by management and is included in the following section.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds – Significant
Deficiency in Internal Controls Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria: The regulations 34 CFR 668.22 notes when a recipient of Title IV grant or loan funds withdraws
from a school after beginning attendance, the University must perform an R2T4 calculation to determine
the amount of Title IV aid earned by the student. If the amount disbursed to the student is greater than the
amount the student earned, the unearned funds must be returned. Additionally, there are specified
communications required to be given to the student by the school per 34 CFR 668.22(3)(a).
Condition/context: We selected a sample of 22 students out of a population of 168 that were identified
by the University as having received some federal assistance and withdrew from the University during the
year under audit. We believe this to be a representative sample of the population. We found one student
had dropped all Spring 2024 courses during the beginning of the term but an R2T4 calculation was not
performed when the University determined the withdraw on January 12, 2024. As there was no R2T4
calculation performed in January 2024, the University did not communicate timely to the student or return
funds within the required time period. The University communicated to the student five months later to
begin the return process.
Questioned costs: No questioned costs were identified as part of this finding.
Cause: The R2T4 calculation was not completed within 30 days of the date of withdraw due to ineffective
and incorrect tracking of the student’s courseload changes. Effect: The lack of an R2T4 calculation being performed when the University became aware of the student’s withdraw caused delay in returning federal funds and required communications to the student.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend the University ensure controls in place are followed and monitored to
ensure R2T4 calculations are performed and reviewed timely.
Views of responsible officials: Management agrees with the finding. A corrective action plan has been
created by management and is included in the following section.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds – Significant
Deficiency in Internal Controls Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria: The regulations 34 CFR 668.22 notes when a recipient of Title IV grant or loan funds withdraws
from a school after beginning attendance, the University must perform an R2T4 calculation to determine
the amount of Title IV aid earned by the student. If the amount disbursed to the student is greater than the
amount the student earned, the unearned funds must be returned. Additionally, there are specified
communications required to be given to the student by the school per 34 CFR 668.22(3)(a).
Condition/context: We selected a sample of 22 students out of a population of 168 that were identified
by the University as having received some federal assistance and withdrew from the University during the
year under audit. We believe this to be a representative sample of the population. We found one student
had dropped all Spring 2024 courses during the beginning of the term but an R2T4 calculation was not
performed when the University determined the withdraw on January 12, 2024. As there was no R2T4
calculation performed in January 2024, the University did not communicate timely to the student or return
funds within the required time period. The University communicated to the student five months later to
begin the return process.
Questioned costs: No questioned costs were identified as part of this finding.
Cause: The R2T4 calculation was not completed within 30 days of the date of withdraw due to ineffective
and incorrect tracking of the student’s courseload changes. Effect: The lack of an R2T4 calculation being performed when the University became aware of the student’s withdraw caused delay in returning federal funds and required communications to the student.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend the University ensure controls in place are followed and monitored to
ensure R2T4 calculations are performed and reviewed timely.
Views of responsible officials: Management agrees with the finding. A corrective action plan has been
created by management and is included in the following section.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds – Significant
Deficiency in Internal Controls Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria: The regulations 34 CFR 668.22 notes when a recipient of Title IV grant or loan funds withdraws
from a school after beginning attendance, the University must perform an R2T4 calculation to determine
the amount of Title IV aid earned by the student. If the amount disbursed to the student is greater than the
amount the student earned, the unearned funds must be returned. Additionally, there are specified
communications required to be given to the student by the school per 34 CFR 668.22(3)(a).
Condition/context: We selected a sample of 22 students out of a population of 168 that were identified
by the University as having received some federal assistance and withdrew from the University during the
year under audit. We believe this to be a representative sample of the population. We found one student
had dropped all Spring 2024 courses during the beginning of the term but an R2T4 calculation was not
performed when the University determined the withdraw on January 12, 2024. As there was no R2T4
calculation performed in January 2024, the University did not communicate timely to the student or return
funds within the required time period. The University communicated to the student five months later to
begin the return process.
Questioned costs: No questioned costs were identified as part of this finding.
Cause: The R2T4 calculation was not completed within 30 days of the date of withdraw due to ineffective
and incorrect tracking of the student’s courseload changes. Effect: The lack of an R2T4 calculation being performed when the University became aware of the student’s withdraw caused delay in returning federal funds and required communications to the student.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend the University ensure controls in place are followed and monitored to
ensure R2T4 calculations are performed and reviewed timely.
Views of responsible officials: Management agrees with the finding. A corrective action plan has been
created by management and is included in the following section.
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency
in Internal Control Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED’s) centralized database for students’ enrollment information. It is the University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes.
34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the
Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the
school discovers that:
1. A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
2. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – From a system generated population of 658 students who received federal aid
and either graduated, withdrew, changed their permanent address, or dropped during the year ended June 30, 2024, we selected a sample of 60 students. We believe this to be a representative sample of the population. The enrollment information and withdrawal or graduation date per the University’s records were compared to the information reported to NSLDS in order to determine if status changes were reported accurately and within the required timeframes.
Of the 60 students who graduated, had an address change, or withdrew, one was not reported to the NSLDS within the required timeframe and had an incorrect status reported to the NSLDS.
Questioned costs: No questioned costs were identified as part of this finding.
Cause – The University’s controls did not capture student status change timely. Effect – The NSLDS database did not include all accurate information in the timeframe required by ED. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine inschool status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans.
Repeat finding – This is not a repeat finding.
Recommendation: We recommend the University develop additional procedures to monitor the accuracy of information reported to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to correct information directly within NSLDS at any time.
Views of responsible officials: Management agrees with the finding. A corrective action plan has been
created by management and is included in the following section.