Federal Program Information: Direct Student Loans Program (ALN 84.268)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Condition: One student disbursement was not reported to COD within 15 calendar days as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 of 40 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendars days.
Identification as a Repeat Finding: This is a repeat of Finding 2023-001.
Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD.
Views of Responsible Officials: As a result of Audit Finding 2023-001 the University had implemented a weekly COD Maintenance Files for Direct Loans and Pell Grants. The 2024-001 Finding is a result of an oversight in the setup of the one student record that caused the information to not be picked up and included in the weekly file. The problem has now been identified and corrected to ensure that such an oversight does not reoccur. Additionally, the University has implemented a new policy in terms of creating and updating student records.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: C. Cash Management: Federal regulations (34 CFR 668.166 (a)(1) & (b)) require that an institution disburse funds requested and received through the G5 system no later than three business days following receipt of those funds from ED. For institutions on the Advance Payment Method, any amount of Title IV funds not disbursed to recipients by the end of the third business day is considered excess cash. ED allows an institution to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to ED any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold.
Condition: The University had three draws of Federal Funds that were held in excess of the allowable timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with cash management requirements.
Questioned Costs: None.
Context: The University had three instances of draws made during the current year that were held in excess of the allowable timeframe.
Identification as a Repeat Finding: There was no similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures and internal control over cash management to ensure they do not have excess cash.
Views of Responsible Officials: Financial Aid and the Controller's Office have implemented a bi-weekly reconciliation process to ensure that any excess funds are disbursed or returned via G5 within the 10 day window.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: C. Cash Management: Federal regulations (34 CFR 668.166 (a)(1) & (b)) require that an institution disburse funds requested and received through the G5 system no later than three business days following receipt of those funds from ED. For institutions on the Advance Payment Method, any amount of Title IV funds not disbursed to recipients by the end of the third business day is considered excess cash. ED allows an institution to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to ED any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold.
Condition: The University had three draws of Federal Funds that were held in excess of the allowable timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with cash management requirements.
Questioned Costs: None.
Context: The University had three instances of draws made during the current year that were held in excess of the allowable timeframe.
Identification as a Repeat Finding: There was no similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures and internal control over cash management to ensure they do not have excess cash.
Views of Responsible Officials: Financial Aid and the Controller's Office have implemented a bi-weekly reconciliation process to ensure that any excess funds are disbursed or returned via G5 within the 10 day window.
Federal Program Information: Pell Grant Program (ALN 84.063), Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Condition: Program Level: Significant data elements were inaccurately reported for certain students.
Campus Level: Significant data elements were inaccurately reported for certain students.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 6 of 40 program level status changes tested, the University did not accurately report one or more significant data elements to NSLDS.
For 1 of 40 campus level status changes tested, the University did not accurately report one or more significant data elements to NSLDS.
Identification as a Repeat Finding: This is a repeat of Finding 2023-003.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS.
Views of Responsible Officials: The University has implemented a plan to review the NSLDS website within 10 Business Days of any submission to ensure that the submitted data has been processed correctly by Clearinghouse and NSLDS.
Federal Program Information: Pell Grant Program (ALN 84.063), Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Condition: Program Level: Significant data elements were inaccurately reported for certain students.
Campus Level: Significant data elements were inaccurately reported for certain students.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 6 of 40 program level status changes tested, the University did not accurately report one or more significant data elements to NSLDS.
For 1 of 40 campus level status changes tested, the University did not accurately report one or more significant data elements to NSLDS.
Identification as a Repeat Finding: This is a repeat of Finding 2023-003.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS.
Views of Responsible Officials: The University has implemented a plan to review the NSLDS website within 10 Business Days of any submission to ensure that the submitted data has been processed correctly by Clearinghouse and NSLDS.
Federal Program Information: Direct Student Loans Program (ALN 84.268)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Condition: One student disbursement was not reported to COD within 15 calendar days as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 of 40 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendars days.
Identification as a Repeat Finding: This is a repeat of Finding 2023-001.
Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD.
Views of Responsible Officials: As a result of Audit Finding 2023-001 the University had implemented a weekly COD Maintenance Files for Direct Loans and Pell Grants. The 2024-001 Finding is a result of an oversight in the setup of the one student record that caused the information to not be picked up and included in the weekly file. The problem has now been identified and corrected to ensure that such an oversight does not reoccur. Additionally, the University has implemented a new policy in terms of creating and updating student records.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: C. Cash Management: Federal regulations (34 CFR 668.166 (a)(1) & (b)) require that an institution disburse funds requested and received through the G5 system no later than three business days following receipt of those funds from ED. For institutions on the Advance Payment Method, any amount of Title IV funds not disbursed to recipients by the end of the third business day is considered excess cash. ED allows an institution to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to ED any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold.
Condition: The University had three draws of Federal Funds that were held in excess of the allowable timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with cash management requirements.
Questioned Costs: None.
Context: The University had three instances of draws made during the current year that were held in excess of the allowable timeframe.
Identification as a Repeat Finding: There was no similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures and internal control over cash management to ensure they do not have excess cash.
Views of Responsible Officials: Financial Aid and the Controller's Office have implemented a bi-weekly reconciliation process to ensure that any excess funds are disbursed or returned via G5 within the 10 day window.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: C. Cash Management: Federal regulations (34 CFR 668.166 (a)(1) & (b)) require that an institution disburse funds requested and received through the G5 system no later than three business days following receipt of those funds from ED. For institutions on the Advance Payment Method, any amount of Title IV funds not disbursed to recipients by the end of the third business day is considered excess cash. ED allows an institution to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to ED any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold.
Condition: The University had three draws of Federal Funds that were held in excess of the allowable timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with cash management requirements.
Questioned Costs: None.
Context: The University had three instances of draws made during the current year that were held in excess of the allowable timeframe.
Identification as a Repeat Finding: There was no similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures and internal control over cash management to ensure they do not have excess cash.
Views of Responsible Officials: Financial Aid and the Controller's Office have implemented a bi-weekly reconciliation process to ensure that any excess funds are disbursed or returned via G5 within the 10 day window.
Federal Program Information: Pell Grant Program (ALN 84.063), Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Condition: Program Level: Significant data elements were inaccurately reported for certain students.
Campus Level: Significant data elements were inaccurately reported for certain students.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 6 of 40 program level status changes tested, the University did not accurately report one or more significant data elements to NSLDS.
For 1 of 40 campus level status changes tested, the University did not accurately report one or more significant data elements to NSLDS.
Identification as a Repeat Finding: This is a repeat of Finding 2023-003.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS.
Views of Responsible Officials: The University has implemented a plan to review the NSLDS website within 10 Business Days of any submission to ensure that the submitted data has been processed correctly by Clearinghouse and NSLDS.
Federal Program Information: Pell Grant Program (ALN 84.063), Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Condition: Program Level: Significant data elements were inaccurately reported for certain students.
Campus Level: Significant data elements were inaccurately reported for certain students.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 6 of 40 program level status changes tested, the University did not accurately report one or more significant data elements to NSLDS.
For 1 of 40 campus level status changes tested, the University did not accurately report one or more significant data elements to NSLDS.
Identification as a Repeat Finding: This is a repeat of Finding 2023-003.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS.
Views of Responsible Officials: The University has implemented a plan to review the NSLDS website within 10 Business Days of any submission to ensure that the submitted data has been processed correctly by Clearinghouse and NSLDS.