2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system provides
institutions with a School Account Statement (SAS) data file which consists of a Cash Summary,
Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is
required to reconcile these files to the institution’s financial records.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.
2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system provides
institutions with a School Account Statement (SAS) data file which consists of a Cash Summary,
Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is
required to reconcile these files to the institution’s financial records.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.
2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system provides
institutions with a School Account Statement (SAS) data file which consists of a Cash Summary,
Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is
required to reconcile these files to the institution’s financial records.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.
2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system provides
institutions with a School Account Statement (SAS) data file which consists of a Cash Summary,
Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is
required to reconcile these files to the institution’s financial records.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.
2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system provides
institutions with a School Account Statement (SAS) data file which consists of a Cash Summary,
Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is
required to reconcile these files to the institution’s financial records.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.
2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system provides
institutions with a School Account Statement (SAS) data file which consists of a Cash Summary,
Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is
required to reconcile these files to the institution’s financial records.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.
2024-003 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for
timely and accurate reporting of a student’s enrollment status and changes in those enrollment
statuses, whether they report directly or via a third-party servicer. When an Institution is made
aware of a change in a student’s enrollment status, the Institution has 60 days to update the
change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there was 1 instance out
of 60 where NLSDS did not reflect accurate or timely reporting of a student's change in
enrollment status. While records were submitted accurately and timely to the Clearinghouse,
those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse
timely and accurately based upon the student’s enrollment status; however, the change in
enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and
untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or
was not reported timely.
Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 participants out of 669 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): Yes, prior year finding 2023-001.
Recommendation: The University should implement controls to ensure that enrollment records
for students are being updated every 60 days, and that those records being submitted to NSLDS
are accurate.
Views of Responsible Officials: Management agrees with the finding.
2024-003 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for
timely and accurate reporting of a student’s enrollment status and changes in those enrollment
statuses, whether they report directly or via a third-party servicer. When an Institution is made
aware of a change in a student’s enrollment status, the Institution has 60 days to update the
change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there was 1 instance out
of 60 where NLSDS did not reflect accurate or timely reporting of a student's change in
enrollment status. While records were submitted accurately and timely to the Clearinghouse,
those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse
timely and accurately based upon the student’s enrollment status; however, the change in
enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and
untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or
was not reported timely.
Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 participants out of 669 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): Yes, prior year finding 2023-001.
Recommendation: The University should implement controls to ensure that enrollment records
for students are being updated every 60 days, and that those records being submitted to NSLDS
are accurate.
Views of Responsible Officials: Management agrees with the finding.
2024-003 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for
timely and accurate reporting of a student’s enrollment status and changes in those enrollment
statuses, whether they report directly or via a third-party servicer. When an Institution is made
aware of a change in a student’s enrollment status, the Institution has 60 days to update the
change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there was 1 instance out
of 60 where NLSDS did not reflect accurate or timely reporting of a student's change in
enrollment status. While records were submitted accurately and timely to the Clearinghouse,
those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse
timely and accurately based upon the student’s enrollment status; however, the change in
enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and
untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or
was not reported timely.
Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 participants out of 669 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): Yes, prior year finding 2023-001.
Recommendation: The University should implement controls to ensure that enrollment records
for students are being updated every 60 days, and that those records being submitted to NSLDS
are accurate.
Views of Responsible Officials: Management agrees with the finding.
2024-003 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for
timely and accurate reporting of a student’s enrollment status and changes in those enrollment
statuses, whether they report directly or via a third-party servicer. When an Institution is made
aware of a change in a student’s enrollment status, the Institution has 60 days to update the
change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there was 1 instance out
of 60 where NLSDS did not reflect accurate or timely reporting of a student's change in
enrollment status. While records were submitted accurately and timely to the Clearinghouse,
those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse
timely and accurately based upon the student’s enrollment status; however, the change in
enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and
untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or
was not reported timely.
Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 participants out of 669 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): Yes, prior year finding 2023-001.
Recommendation: The University should implement controls to ensure that enrollment records
for students are being updated every 60 days, and that those records being submitted to NSLDS
are accurate.
Views of Responsible Officials: Management agrees with the finding.
2024-003 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for
timely and accurate reporting of a student’s enrollment status and changes in those enrollment
statuses, whether they report directly or via a third-party servicer. When an Institution is made
aware of a change in a student’s enrollment status, the Institution has 60 days to update the
change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there was 1 instance out
of 60 where NLSDS did not reflect accurate or timely reporting of a student's change in
enrollment status. While records were submitted accurately and timely to the Clearinghouse,
those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse
timely and accurately based upon the student’s enrollment status; however, the change in
enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and
untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or
was not reported timely.
Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 participants out of 669 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): Yes, prior year finding 2023-001.
Recommendation: The University should implement controls to ensure that enrollment records
for students are being updated every 60 days, and that those records being submitted to NSLDS
are accurate.
Views of Responsible Officials: Management agrees with the finding.
2024-003 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for
timely and accurate reporting of a student’s enrollment status and changes in those enrollment
statuses, whether they report directly or via a third-party servicer. When an Institution is made
aware of a change in a student’s enrollment status, the Institution has 60 days to update the
change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there was 1 instance out
of 60 where NLSDS did not reflect accurate or timely reporting of a student's change in
enrollment status. While records were submitted accurately and timely to the Clearinghouse,
those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse
timely and accurately based upon the student’s enrollment status; however, the change in
enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and
untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or
was not reported timely.
Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 participants out of 669 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): Yes, prior year finding 2023-001.
Recommendation: The University should implement controls to ensure that enrollment records
for students are being updated every 60 days, and that those records being submitted to NSLDS
are accurate.
Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.
2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system provides
institutions with a School Account Statement (SAS) data file which consists of a Cash Summary,
Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is
required to reconcile these files to the institution’s financial records.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.
2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system provides
institutions with a School Account Statement (SAS) data file which consists of a Cash Summary,
Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is
required to reconcile these files to the institution’s financial records.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.
2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system provides
institutions with a School Account Statement (SAS) data file which consists of a Cash Summary,
Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is
required to reconcile these files to the institution’s financial records.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.
2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system provides
institutions with a School Account Statement (SAS) data file which consists of a Cash Summary,
Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is
required to reconcile these files to the institution’s financial records.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.
2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system provides
institutions with a School Account Statement (SAS) data file which consists of a Cash Summary,
Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is
required to reconcile these files to the institution’s financial records.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.
2024-002 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Borrower Data and Reconciliation
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Each month, the Common Origination and Disbursement (COD) system provides
institutions with a School Account Statement (SAS) data file which consists of a Cash Summary,
Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is
required to reconcile these files to the institution’s financial records.
Condition: The SAS reconciliations were not performed during the year.Cause: The University did not have internal controls to provide for the reconciliations of the SAS
data file.
Effect: Records maintained by the COD may not agree to the University’s records.
Questioned Costs: None reported.
Context/Sampling: The SAS monthly reconciliations were not performed for the whole year.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the University implement internal controls to provide for the
reconciliation of the SAS data file.
Views of Responsible Officials: Management agrees with the finding.
2024-003 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for
timely and accurate reporting of a student’s enrollment status and changes in those enrollment
statuses, whether they report directly or via a third-party servicer. When an Institution is made
aware of a change in a student’s enrollment status, the Institution has 60 days to update the
change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there was 1 instance out
of 60 where NLSDS did not reflect accurate or timely reporting of a student's change in
enrollment status. While records were submitted accurately and timely to the Clearinghouse,
those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse
timely and accurately based upon the student’s enrollment status; however, the change in
enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and
untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or
was not reported timely.
Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 participants out of 669 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): Yes, prior year finding 2023-001.
Recommendation: The University should implement controls to ensure that enrollment records
for students are being updated every 60 days, and that those records being submitted to NSLDS
are accurate.
Views of Responsible Officials: Management agrees with the finding.
2024-003 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for
timely and accurate reporting of a student’s enrollment status and changes in those enrollment
statuses, whether they report directly or via a third-party servicer. When an Institution is made
aware of a change in a student’s enrollment status, the Institution has 60 days to update the
change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there was 1 instance out
of 60 where NLSDS did not reflect accurate or timely reporting of a student's change in
enrollment status. While records were submitted accurately and timely to the Clearinghouse,
those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse
timely and accurately based upon the student’s enrollment status; however, the change in
enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and
untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or
was not reported timely.
Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 participants out of 669 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): Yes, prior year finding 2023-001.
Recommendation: The University should implement controls to ensure that enrollment records
for students are being updated every 60 days, and that those records being submitted to NSLDS
are accurate.
Views of Responsible Officials: Management agrees with the finding.
2024-003 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for
timely and accurate reporting of a student’s enrollment status and changes in those enrollment
statuses, whether they report directly or via a third-party servicer. When an Institution is made
aware of a change in a student’s enrollment status, the Institution has 60 days to update the
change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there was 1 instance out
of 60 where NLSDS did not reflect accurate or timely reporting of a student's change in
enrollment status. While records were submitted accurately and timely to the Clearinghouse,
those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse
timely and accurately based upon the student’s enrollment status; however, the change in
enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and
untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or
was not reported timely.
Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 participants out of 669 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): Yes, prior year finding 2023-001.
Recommendation: The University should implement controls to ensure that enrollment records
for students are being updated every 60 days, and that those records being submitted to NSLDS
are accurate.
Views of Responsible Officials: Management agrees with the finding.
2024-003 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for
timely and accurate reporting of a student’s enrollment status and changes in those enrollment
statuses, whether they report directly or via a third-party servicer. When an Institution is made
aware of a change in a student’s enrollment status, the Institution has 60 days to update the
change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there was 1 instance out
of 60 where NLSDS did not reflect accurate or timely reporting of a student's change in
enrollment status. While records were submitted accurately and timely to the Clearinghouse,
those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse
timely and accurately based upon the student’s enrollment status; however, the change in
enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and
untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or
was not reported timely.
Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 participants out of 669 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): Yes, prior year finding 2023-001.
Recommendation: The University should implement controls to ensure that enrollment records
for students are being updated every 60 days, and that those records being submitted to NSLDS
are accurate.
Views of Responsible Officials: Management agrees with the finding.
2024-003 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for
timely and accurate reporting of a student’s enrollment status and changes in those enrollment
statuses, whether they report directly or via a third-party servicer. When an Institution is made
aware of a change in a student’s enrollment status, the Institution has 60 days to update the
change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there was 1 instance out
of 60 where NLSDS did not reflect accurate or timely reporting of a student's change in
enrollment status. While records were submitted accurately and timely to the Clearinghouse,
those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse
timely and accurately based upon the student’s enrollment status; however, the change in
enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and
untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or
was not reported timely.
Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 participants out of 669 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): Yes, prior year finding 2023-001.
Recommendation: The University should implement controls to ensure that enrollment records
for students are being updated every 60 days, and that those records being submitted to NSLDS
are accurate.
Views of Responsible Officials: Management agrees with the finding.
2024-003 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for
timely and accurate reporting of a student’s enrollment status and changes in those enrollment
statuses, whether they report directly or via a third-party servicer. When an Institution is made
aware of a change in a student’s enrollment status, the Institution has 60 days to update the
change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there was 1 instance out
of 60 where NLSDS did not reflect accurate or timely reporting of a student's change in
enrollment status. While records were submitted accurately and timely to the Clearinghouse,
those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse
timely and accurately based upon the student’s enrollment status; however, the change in
enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and
untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or
was not reported timely.
Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 participants out of 669 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): Yes, prior year finding 2023-001.
Recommendation: The University should implement controls to ensure that enrollment records
for students are being updated every 60 days, and that those records being submitted to NSLDS
are accurate.
Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.