Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2023-2024 Award Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Additionally, the University was not able to provide support of academic activity for some distance education students who had no passing grades to determine if they began attendance.
Criteria: 34 CFR 668.22
Questioned Costs: $18,809
Context: Out of 22 students tested, 8 total students had errors:
• 3 students had late returns totaling $7,776 in FDL and Pell.
• 6 students had incorrect calculations resulting in $1,568 in FDL and Pell being under-returned and $76 in FDL being over-returned.
• 3 distance education students did not have records of academic activity retained by the University. These students received $9,465 in FDL and Pell.
These were not corrected during the audit.
Cause: Misunderstanding of modular withdrawal R2T4 calculations. Additionally, the University switched systems used to administer distance education programs.
Effect: Return of Title IV funds were not performed accurately and timely.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend the University perform additional training on R2T4 regulations and implement a second review on R2T4 calculations performed. We also recommend the University retain academic activity for all distance education students without passing grades.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2023-2024 Award Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Additionally, the University was not able to provide support of academic activity for some distance education students who had no passing grades to determine if they began attendance.
Criteria: 34 CFR 668.22
Questioned Costs: $18,809
Context: Out of 22 students tested, 8 total students had errors:
• 3 students had late returns totaling $7,776 in FDL and Pell.
• 6 students had incorrect calculations resulting in $1,568 in FDL and Pell being under-returned and $76 in FDL being over-returned.
• 3 distance education students did not have records of academic activity retained by the University. These students received $9,465 in FDL and Pell.
These were not corrected during the audit.
Cause: Misunderstanding of modular withdrawal R2T4 calculations. Additionally, the University switched systems used to administer distance education programs.
Effect: Return of Title IV funds were not performed accurately and timely.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend the University perform additional training on R2T4 regulations and implement a second review on R2T4 calculations performed. We also recommend the University retain academic activity for all distance education students without passing grades.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2023-2024 Award Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Additionally, the University was not able to provide support of academic activity for some distance education students who had no passing grades to determine if they began attendance.
Criteria: 34 CFR 668.22
Questioned Costs: $18,809
Context: Out of 22 students tested, 8 total students had errors:
• 3 students had late returns totaling $7,776 in FDL and Pell.
• 6 students had incorrect calculations resulting in $1,568 in FDL and Pell being under-returned and $76 in FDL being over-returned.
• 3 distance education students did not have records of academic activity retained by the University. These students received $9,465 in FDL and Pell.
These were not corrected during the audit.
Cause: Misunderstanding of modular withdrawal R2T4 calculations. Additionally, the University switched systems used to administer distance education programs.
Effect: Return of Title IV funds were not performed accurately and timely.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend the University perform additional training on R2T4 regulations and implement a second review on R2T4 calculations performed. We also recommend the University retain academic activity for all distance education students without passing grades.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently documented its security risk assessment and safeguards, including financial aid applications, or implemented multi-factor authentication on all systems containing personally identifiable information (PII).
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently documented its security risk assessment and safeguards, including financial aid applications, or implemented multi-factor authentication on all systems containing personally identifiable information (PII).
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently documented its security risk assessment and safeguards, including financial aid applications, or implemented multi-factor authentication on all systems containing personally identifiable information (PII).
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently documented its security risk assessment and safeguards, including financial aid applications, or implemented multi-factor authentication on all systems containing personally identifiable information (PII).
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently documented its security risk assessment and safeguards, including financial aid applications, or implemented multi-factor authentication on all systems containing personally identifiable information (PII).
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently documented its security risk assessment and safeguards, including financial aid applications, or implemented multi-factor authentication on all systems containing personally identifiable information (PII).
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate TRIO Reporting DEPARTMENT OF EDUCATION
ALN #: 84.042A
Federal Award Identification #: P042A201146
Condition: The University did not report accurate information on key line items of the Annual Performance Report for all students.
Criteria: 34 CFR 646.22(a)
Questioned Costs: $0
Context: 10 out of 37 students tested had inaccurate information reported on key line items of the Annual Performance Report.
Cause: This was an oversight by the University.
Effect: Inaccurate information was reported on the Annual Performance Report.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University have a review process to ensure each student's information is reconciled between the University's records and the system used to track TRIO participants and populate the Annual Performance Report.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2023-2024 Award Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Additionally, the University was not able to provide support of academic activity for some distance education students who had no passing grades to determine if they began attendance.
Criteria: 34 CFR 668.22
Questioned Costs: $18,809
Context: Out of 22 students tested, 8 total students had errors:
• 3 students had late returns totaling $7,776 in FDL and Pell.
• 6 students had incorrect calculations resulting in $1,568 in FDL and Pell being under-returned and $76 in FDL being over-returned.
• 3 distance education students did not have records of academic activity retained by the University. These students received $9,465 in FDL and Pell.
These were not corrected during the audit.
Cause: Misunderstanding of modular withdrawal R2T4 calculations. Additionally, the University switched systems used to administer distance education programs.
Effect: Return of Title IV funds were not performed accurately and timely.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend the University perform additional training on R2T4 regulations and implement a second review on R2T4 calculations performed. We also recommend the University retain academic activity for all distance education students without passing grades.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2023-2024 Award Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Additionally, the University was not able to provide support of academic activity for some distance education students who had no passing grades to determine if they began attendance.
Criteria: 34 CFR 668.22
Questioned Costs: $18,809
Context: Out of 22 students tested, 8 total students had errors:
• 3 students had late returns totaling $7,776 in FDL and Pell.
• 6 students had incorrect calculations resulting in $1,568 in FDL and Pell being under-returned and $76 in FDL being over-returned.
• 3 distance education students did not have records of academic activity retained by the University. These students received $9,465 in FDL and Pell.
These were not corrected during the audit.
Cause: Misunderstanding of modular withdrawal R2T4 calculations. Additionally, the University switched systems used to administer distance education programs.
Effect: Return of Title IV funds were not performed accurately and timely.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend the University perform additional training on R2T4 regulations and implement a second review on R2T4 calculations performed. We also recommend the University retain academic activity for all distance education students without passing grades.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2023-2024 Award Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Additionally, the University was not able to provide support of academic activity for some distance education students who had no passing grades to determine if they began attendance.
Criteria: 34 CFR 668.22
Questioned Costs: $18,809
Context: Out of 22 students tested, 8 total students had errors:
• 3 students had late returns totaling $7,776 in FDL and Pell.
• 6 students had incorrect calculations resulting in $1,568 in FDL and Pell being under-returned and $76 in FDL being over-returned.
• 3 distance education students did not have records of academic activity retained by the University. These students received $9,465 in FDL and Pell.
These were not corrected during the audit.
Cause: Misunderstanding of modular withdrawal R2T4 calculations. Additionally, the University switched systems used to administer distance education programs.
Effect: Return of Title IV funds were not performed accurately and timely.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend the University perform additional training on R2T4 regulations and implement a second review on R2T4 calculations performed. We also recommend the University retain academic activity for all distance education students without passing grades.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently documented its security risk assessment and safeguards, including financial aid applications, or implemented multi-factor authentication on all systems containing personally identifiable information (PII).
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently documented its security risk assessment and safeguards, including financial aid applications, or implemented multi-factor authentication on all systems containing personally identifiable information (PII).
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently documented its security risk assessment and safeguards, including financial aid applications, or implemented multi-factor authentication on all systems containing personally identifiable information (PII).
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently documented its security risk assessment and safeguards, including financial aid applications, or implemented multi-factor authentication on all systems containing personally identifiable information (PII).
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently documented its security risk assessment and safeguards, including financial aid applications, or implemented multi-factor authentication on all systems containing personally identifiable information (PII).
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not sufficiently documented its security risk assessment and safeguards, including financial aid applications, or implemented multi-factor authentication on all systems containing personally identifiable information (PII).
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate TRIO Reporting DEPARTMENT OF EDUCATION
ALN #: 84.042A
Federal Award Identification #: P042A201146
Condition: The University did not report accurate information on key line items of the Annual Performance Report for all students.
Criteria: 34 CFR 646.22(a)
Questioned Costs: $0
Context: 10 out of 37 students tested had inaccurate information reported on key line items of the Annual Performance Report.
Cause: This was an oversight by the University.
Effect: Inaccurate information was reported on the Annual Performance Report.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University have a review process to ensure each student's information is reconciled between the University's records and the system used to track TRIO participants and populate the Annual Performance Report.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.