Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner.
Criteria: 34 CFR 685.309
Questioned Costs: $0
Context: Out of 54 students tested, 45 students had incorrect enrollment statuses reported, of which seven were withdrawals. Additionally, out of 14 students tested, seven students had incorrect program reporting to NSLDS.
Cause: The University’s process has been manual to update all NSLDS reporting by student.
Effect: Inaccurate reporting can impact a student’s loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc.
Identification as repeat finding, if applicable: Yes, 2023-001 and 2022-002
Recommendation: We recommend the University put a system in place to ensure that all students are being reported to NSLDS, and that the University is completing spot checks of enrollment statuses to NSLDS.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: There were four incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups and late notifications of students not attending, resulting in late returns.
Criteria: 34 CFR 668.22
Questioned Costs: $245
Context: Out of 8 students, two students who withdrew during the audit period tested had funds returned late due to late notifications of non-attendance. Three students had incorrect calculations due to incorrect calendar set ups and needing to recalculate pell for classes the students began attendance in prior to performing the return calculation. This resulted in Pell owed back to the government of $78 and FDL owed back of $167 at fiscal year-end. Additionally, one student was not offered a post withdrawal disbursement of $292 of loans. Because the dollar amounts are small and the error rate is higher, this is classified as a significant deficiency. All students were corrected during the audit process.
Cause: The calendar setups for fall 2023 were not set up properly. Additionally, notifications of nonattendance were not sent to financial aid timely to perform return calculations.
Effect: Incorrect amount of unearned Title IV funds returned and lack of offering a post withdrawal disbursement.
Identification as repeat finding, if applicable: Yes, 2023-002, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005.
Recommendation: We recommend the University review the calendar set ups and ensure the proper number of days are used in the calculations. Additionally, we recommend the University implement a way to notify financial aid timely when students are not attending so a return calculation can be done timely.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: There were four incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups and late notifications of students not attending, resulting in late returns.
Criteria: 34 CFR 668.22
Questioned Costs: $245
Context: Out of 8 students, two students who withdrew during the audit period tested had funds returned late due to late notifications of non-attendance. Three students had incorrect calculations due to incorrect calendar set ups and needing to recalculate pell for classes the students began attendance in prior to performing the return calculation. This resulted in Pell owed back to the government of $78 and FDL owed back of $167 at fiscal year-end. Additionally, one student was not offered a post withdrawal disbursement of $292 of loans. Because the dollar amounts are small and the error rate is higher, this is classified as a significant deficiency. All students were corrected during the audit process.
Cause: The calendar setups for fall 2023 were not set up properly. Additionally, notifications of nonattendance were not sent to financial aid timely to perform return calculations.
Effect: Incorrect amount of unearned Title IV funds returned and lack of offering a post withdrawal disbursement.
Identification as repeat finding, if applicable: Yes, 2023-002, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005.
Recommendation: We recommend the University review the calendar set ups and ensure the proper number of days are used in the calculations. Additionally, we recommend the University implement a way to notify financial aid timely when students are not attending so a return calculation can be done timely.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Documentation of Exit Counseling Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not retain evidence or provide exit counseling to all students who left or did not send exit counseling instructions timely.
Criteria: 34 CFR 685.304(b)
Questioned Costs: $0
Context: Out of 37 students tested for exit counseling, six students did not have any documentation of exit counseling being sent. The University is in the process of sending these students exit counseling notifications.
Cause: These students were marked in the system as active, so they were not picked up with the report to send exit counseling.
Effect: Documentation of exit counseling was not available. Exit counseling packets assist in reducing the default rate. The default rate for the University was 5.5% in 2019, 20.5% in 2018, and 21.8% in 2017. Official rates for 2020 and 2021 are listed at 0% due to COVID waivers.
Identification as repeat finding, if applicable: Yes, 2023-003.
Recommendation: We recommend the University implement a process where all students leaving the University are notified of exit counseling requirements and documentation is retained.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Disbursements to Ineligible Students DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: Two students who did not begin attendance in a semester were paid federal aid.
Criteria: 34 CFR 668.32(a), 34 CFR 600.2
Questioned Costs: $9,500
Context: Out of 51 tested for eligibility, two students did not begin attendance in an eligible program. One student’s aid was returned prior to the end of the semester but beyond the allowable 30 days. The other student’s aid was returned shortly after fiscal year-end.
Cause: The system check to verify attendance did not catch these students as not having begun the semester.
Effect: Federal aid was paid to an ineligible student.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University compare a listing of students who have begun attendance to federal aid paid and return any federal aid paid to ineligible students.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Disbursements to Ineligible Students DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: Two students who did not begin attendance in a semester were paid federal aid.
Criteria: 34 CFR 668.32(a), 34 CFR 600.2
Questioned Costs: $9,500
Context: Out of 51 tested for eligibility, two students did not begin attendance in an eligible program. One student’s aid was returned prior to the end of the semester but beyond the allowable 30 days. The other student’s aid was returned shortly after fiscal year-end.
Cause: The system check to verify attendance did not catch these students as not having begun the semester.
Effect: Federal aid was paid to an ineligible student.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University compare a listing of students who have begun attendance to federal aid paid and return any federal aid paid to ineligible students.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner.
Criteria: 34 CFR 685.309
Questioned Costs: $0
Context: Out of 54 students tested, 45 students had incorrect enrollment statuses reported, of which seven were withdrawals. Additionally, out of 14 students tested, seven students had incorrect program reporting to NSLDS.
Cause: The University’s process has been manual to update all NSLDS reporting by student.
Effect: Inaccurate reporting can impact a student’s loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc.
Identification as repeat finding, if applicable: Yes, 2023-001 and 2022-002
Recommendation: We recommend the University put a system in place to ensure that all students are being reported to NSLDS, and that the University is completing spot checks of enrollment statuses to NSLDS.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: There were four incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups and late notifications of students not attending, resulting in late returns.
Criteria: 34 CFR 668.22
Questioned Costs: $245
Context: Out of 8 students, two students who withdrew during the audit period tested had funds returned late due to late notifications of non-attendance. Three students had incorrect calculations due to incorrect calendar set ups and needing to recalculate pell for classes the students began attendance in prior to performing the return calculation. This resulted in Pell owed back to the government of $78 and FDL owed back of $167 at fiscal year-end. Additionally, one student was not offered a post withdrawal disbursement of $292 of loans. Because the dollar amounts are small and the error rate is higher, this is classified as a significant deficiency. All students were corrected during the audit process.
Cause: The calendar setups for fall 2023 were not set up properly. Additionally, notifications of nonattendance were not sent to financial aid timely to perform return calculations.
Effect: Incorrect amount of unearned Title IV funds returned and lack of offering a post withdrawal disbursement.
Identification as repeat finding, if applicable: Yes, 2023-002, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005.
Recommendation: We recommend the University review the calendar set ups and ensure the proper number of days are used in the calculations. Additionally, we recommend the University implement a way to notify financial aid timely when students are not attending so a return calculation can be done timely.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: There were four incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups and late notifications of students not attending, resulting in late returns.
Criteria: 34 CFR 668.22
Questioned Costs: $245
Context: Out of 8 students, two students who withdrew during the audit period tested had funds returned late due to late notifications of non-attendance. Three students had incorrect calculations due to incorrect calendar set ups and needing to recalculate pell for classes the students began attendance in prior to performing the return calculation. This resulted in Pell owed back to the government of $78 and FDL owed back of $167 at fiscal year-end. Additionally, one student was not offered a post withdrawal disbursement of $292 of loans. Because the dollar amounts are small and the error rate is higher, this is classified as a significant deficiency. All students were corrected during the audit process.
Cause: The calendar setups for fall 2023 were not set up properly. Additionally, notifications of nonattendance were not sent to financial aid timely to perform return calculations.
Effect: Incorrect amount of unearned Title IV funds returned and lack of offering a post withdrawal disbursement.
Identification as repeat finding, if applicable: Yes, 2023-002, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005.
Recommendation: We recommend the University review the calendar set ups and ensure the proper number of days are used in the calculations. Additionally, we recommend the University implement a way to notify financial aid timely when students are not attending so a return calculation can be done timely.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Documentation of Exit Counseling Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not retain evidence or provide exit counseling to all students who left or did not send exit counseling instructions timely.
Criteria: 34 CFR 685.304(b)
Questioned Costs: $0
Context: Out of 37 students tested for exit counseling, six students did not have any documentation of exit counseling being sent. The University is in the process of sending these students exit counseling notifications.
Cause: These students were marked in the system as active, so they were not picked up with the report to send exit counseling.
Effect: Documentation of exit counseling was not available. Exit counseling packets assist in reducing the default rate. The default rate for the University was 5.5% in 2019, 20.5% in 2018, and 21.8% in 2017. Official rates for 2020 and 2021 are listed at 0% due to COVID waivers.
Identification as repeat finding, if applicable: Yes, 2023-003.
Recommendation: We recommend the University implement a process where all students leaving the University are notified of exit counseling requirements and documentation is retained.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Disbursements to Ineligible Students DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: Two students who did not begin attendance in a semester were paid federal aid.
Criteria: 34 CFR 668.32(a), 34 CFR 600.2
Questioned Costs: $9,500
Context: Out of 51 tested for eligibility, two students did not begin attendance in an eligible program. One student’s aid was returned prior to the end of the semester but beyond the allowable 30 days. The other student’s aid was returned shortly after fiscal year-end.
Cause: The system check to verify attendance did not catch these students as not having begun the semester.
Effect: Federal aid was paid to an ineligible student.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University compare a listing of students who have begun attendance to federal aid paid and return any federal aid paid to ineligible students.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Disbursements to Ineligible Students DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: Two students who did not begin attendance in a semester were paid federal aid.
Criteria: 34 CFR 668.32(a), 34 CFR 600.2
Questioned Costs: $9,500
Context: Out of 51 tested for eligibility, two students did not begin attendance in an eligible program. One student’s aid was returned prior to the end of the semester but beyond the allowable 30 days. The other student’s aid was returned shortly after fiscal year-end.
Cause: The system check to verify attendance did not catch these students as not having begun the semester.
Effect: Federal aid was paid to an ineligible student.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University compare a listing of students who have begun attendance to federal aid paid and return any federal aid paid to ineligible students.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.