FAC Explorer

Audit 338706

FY End
2024-06-30
Total Expended
$7.08M
Findings
18
Programs
4
Organization: Cleary University (MI)
Year: 2024 Accepted: 2025-01-17
Auditor: Capincrouse LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
519609 2024-001 Material Weakness Yes N
519610 2024-001 Material Weakness Yes N
519611 2024-001 Material Weakness Yes N
519612 2024-002 Significant Deficiency - N
519613 2024-002 Significant Deficiency - N
519614 2024-003 - Yes N
519615 2024-003 - Yes N
519616 2024-003 - Yes N
519617 2024-003 - Yes N
1096051 2024-001 Material Weakness Yes N
1096052 2024-001 Material Weakness Yes N
1096053 2024-001 Material Weakness Yes N
1096054 2024-002 Significant Deficiency - N
1096055 2024-002 Significant Deficiency - N
1096056 2024-003 - Yes N
1096057 2024-003 - Yes N
1096058 2024-003 - Yes N
1096059 2024-003 - Yes N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $5.49M Yes 3
84.063 Federal Pell Grant Program $1.49M Yes 3
84.007 Federal Supplemental Educational Opportunity Grants $74,929 Yes 2
84.033 Federal Work-Study Program $26,250 Yes 1

Contacts

Name Title Type
JTGMMMLAU6D4 Megan Temby Auditee
8006861883 Tyler Vanderven, CPA Auditor
No contacts on file

Notes to SEFA

Title: RELATIONSHIP TO FINANCIAL STATEMENTS Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Cleary University (University) under programs of the federal government for the year ended June 30, 2024. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. See the notes to the SEFA for chart/table.
Title: SUBRECIPIENTS, NON-CASH ASSISTANCE, FEDERAL INSURANCE, LOANS, AND LOAN GUARANTEES Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Cleary University (University) under programs of the federal government for the year ended June 30, 2024. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The University did not provide any federal funds to subrecipients nor did they receive any federal non-cash assistance, insurance, or loan guarantees. The University did receive a COVD-19 economic injury disaster loan, ALN 59.008 from the Small Business Administration (SBA) in 2020, however since SBA has indicated that the only continuing compliance requirement is repayment, it is not included on the schedule after the initial year of the loan.
Title: ZONE ALTERNATIVE COMPLIANCE Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Cleary University (University) under programs of the federal government for the year ended June 30, 2024. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Beginning in November 2023, the University was operating under the Provisional Certification Alternative for failure to meet the Department of Education's standards of financial responsibility. The University must comply with all the requirements specified for the Provisional Certification Alternative including the Zone Alternative. As part of the audit procedures, the School's compliance with the Zone Alternative including their administration of the heightened cash monitoring payment method, disbursing aid and paying out credit balances before requesting reimbursement and timely notification requirements was tested. No non-compliance with the requirements was noted.
Title: INSTITUTION ELIGIBILITY LIMITATIONS IN ACCORDANCE WITH 34 CFR 600.7(a)1 Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Cleary University (University) under programs of the federal government for the year ended June 30, 2024. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. To maintain institutional eligibility to participate in the Department of Education’s Title IV financial aid programs, the University is required to comply with 34 CFR 600.7(a)1 which limits the number of correspondence courses, the number of students enrolled in correspondence courses, the number of incarcerated students enrolled and the number of students enrolled without a high school diploma or recognized equivalent. As part of the audit procedures, compliance with these limitations was tested. No non-compliance with the requirements was noted.

Finding Details

Finding 2024-001
Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.268, 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 accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $8,683 Context: Out of 23 students tested, 4 students had returns totaling $7,626 ranging from 18 to 123 days late. 1 student had $1,429 of federal direct loans returned but then incorrectly disbursed back to the student. These funds were returned back to the Department of Education in September 2024, 247 days late. 1 student had an R2T4 calculated but the unearned funds totaling $5,912 have not yet been returned. 6 students had miscalculations due to Pell not being recalculated for classes the student didn’t begin attendance prior to the R2T4 calculation which resulted in $1,342 of Pell under returned and $463 of federal direct loans (FDL) over returned. 4 students had miscalculations due to incorrect break days used resulting in $9 of Pell and $197 of FDL over returned. Cause: Complexity of R2T4 calculations. Break days not properly factored into the calculation. Pell not properly recalculated prior to the R2T4 calculation for classes students didn't begin attendance in. Effect: Noncompliance with R2T4 regulations Identification as repeat finding, if applicable: 2023-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students’ R2T4 calendars, calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-001
Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.268, 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 accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $8,683 Context: Out of 23 students tested, 4 students had returns totaling $7,626 ranging from 18 to 123 days late. 1 student had $1,429 of federal direct loans returned but then incorrectly disbursed back to the student. These funds were returned back to the Department of Education in September 2024, 247 days late. 1 student had an R2T4 calculated but the unearned funds totaling $5,912 have not yet been returned. 6 students had miscalculations due to Pell not being recalculated for classes the student didn’t begin attendance prior to the R2T4 calculation which resulted in $1,342 of Pell under returned and $463 of federal direct loans (FDL) over returned. 4 students had miscalculations due to incorrect break days used resulting in $9 of Pell and $197 of FDL over returned. Cause: Complexity of R2T4 calculations. Break days not properly factored into the calculation. Pell not properly recalculated prior to the R2T4 calculation for classes students didn't begin attendance in. Effect: Noncompliance with R2T4 regulations Identification as repeat finding, if applicable: 2023-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students’ R2T4 calendars, calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-001
Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.268, 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 accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $8,683 Context: Out of 23 students tested, 4 students had returns totaling $7,626 ranging from 18 to 123 days late. 1 student had $1,429 of federal direct loans returned but then incorrectly disbursed back to the student. These funds were returned back to the Department of Education in September 2024, 247 days late. 1 student had an R2T4 calculated but the unearned funds totaling $5,912 have not yet been returned. 6 students had miscalculations due to Pell not being recalculated for classes the student didn’t begin attendance prior to the R2T4 calculation which resulted in $1,342 of Pell under returned and $463 of federal direct loans (FDL) over returned. 4 students had miscalculations due to incorrect break days used resulting in $9 of Pell and $197 of FDL over returned. Cause: Complexity of R2T4 calculations. Break days not properly factored into the calculation. Pell not properly recalculated prior to the R2T4 calculation for classes students didn't begin attendance in. Effect: Noncompliance with R2T4 regulations Identification as repeat finding, if applicable: 2023-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students’ R2T4 calendars, calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-002
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: The NSLDS enrollment status was not properly reported for some students, primarily those who withdrew from the University. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 77 students tested, 5 students who withdrew were still being reported as enrolled to NSLDS. 2 students were reported as “no record found” but both had federal direct loans disbursed during the year. Cause: The registrar's office was not completing timely reconciliations of enrollment statuses throughout the year. Effect: The incorrect reporting impacts the student's loan grace period, in school deferment eligibility, beginning loans payments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University put a system in place to ensure that students who withdraw either officially or unofficially during a term be checked for proper reporting to NSLDS as part of the R2T4 process. We also recommend that the University is periodically completing reconciliations of enrollment statuses and completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-002
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: The NSLDS enrollment status was not properly reported for some students, primarily those who withdrew from the University. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 77 students tested, 5 students who withdrew were still being reported as enrolled to NSLDS. 2 students were reported as “no record found” but both had federal direct loans disbursed during the year. Cause: The registrar's office was not completing timely reconciliations of enrollment statuses throughout the year. Effect: The incorrect reporting impacts the student's loan grace period, in school deferment eligibility, beginning loans payments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University put a system in place to ensure that students who withdraw either officially or unofficially during a term be checked for proper reporting to NSLDS as part of the R2T4 process. We also recommend that the University is periodically completing reconciliations of enrollment statuses and completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-003
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has made progress from the prior year on GLBA compliance. The University has one remaining area left to implement relating to sufficient vendor management policies and reviews. Cause: The University has prioritized resources to address and document compliance with multi-factor authentication and risk assessment evaluation before implementing the vendor management requirements of GLBA. Effect: The University has not adequately addressed all the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the University allocate sufficient resources to address all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-003
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has made progress from the prior year on GLBA compliance. The University has one remaining area left to implement relating to sufficient vendor management policies and reviews. Cause: The University has prioritized resources to address and document compliance with multi-factor authentication and risk assessment evaluation before implementing the vendor management requirements of GLBA. Effect: The University has not adequately addressed all the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the University allocate sufficient resources to address all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-003
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has made progress from the prior year on GLBA compliance. The University has one remaining area left to implement relating to sufficient vendor management policies and reviews. Cause: The University has prioritized resources to address and document compliance with multi-factor authentication and risk assessment evaluation before implementing the vendor management requirements of GLBA. Effect: The University has not adequately addressed all the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the University allocate sufficient resources to address all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-003
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has made progress from the prior year on GLBA compliance. The University has one remaining area left to implement relating to sufficient vendor management policies and reviews. Cause: The University has prioritized resources to address and document compliance with multi-factor authentication and risk assessment evaluation before implementing the vendor management requirements of GLBA. Effect: The University has not adequately addressed all the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the University allocate sufficient resources to address all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-001
Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.268, 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 accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $8,683 Context: Out of 23 students tested, 4 students had returns totaling $7,626 ranging from 18 to 123 days late. 1 student had $1,429 of federal direct loans returned but then incorrectly disbursed back to the student. These funds were returned back to the Department of Education in September 2024, 247 days late. 1 student had an R2T4 calculated but the unearned funds totaling $5,912 have not yet been returned. 6 students had miscalculations due to Pell not being recalculated for classes the student didn’t begin attendance prior to the R2T4 calculation which resulted in $1,342 of Pell under returned and $463 of federal direct loans (FDL) over returned. 4 students had miscalculations due to incorrect break days used resulting in $9 of Pell and $197 of FDL over returned. Cause: Complexity of R2T4 calculations. Break days not properly factored into the calculation. Pell not properly recalculated prior to the R2T4 calculation for classes students didn't begin attendance in. Effect: Noncompliance with R2T4 regulations Identification as repeat finding, if applicable: 2023-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students’ R2T4 calendars, calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-001
Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.268, 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 accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $8,683 Context: Out of 23 students tested, 4 students had returns totaling $7,626 ranging from 18 to 123 days late. 1 student had $1,429 of federal direct loans returned but then incorrectly disbursed back to the student. These funds were returned back to the Department of Education in September 2024, 247 days late. 1 student had an R2T4 calculated but the unearned funds totaling $5,912 have not yet been returned. 6 students had miscalculations due to Pell not being recalculated for classes the student didn’t begin attendance prior to the R2T4 calculation which resulted in $1,342 of Pell under returned and $463 of federal direct loans (FDL) over returned. 4 students had miscalculations due to incorrect break days used resulting in $9 of Pell and $197 of FDL over returned. Cause: Complexity of R2T4 calculations. Break days not properly factored into the calculation. Pell not properly recalculated prior to the R2T4 calculation for classes students didn't begin attendance in. Effect: Noncompliance with R2T4 regulations Identification as repeat finding, if applicable: 2023-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students’ R2T4 calendars, calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-001
Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.268, 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 accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $8,683 Context: Out of 23 students tested, 4 students had returns totaling $7,626 ranging from 18 to 123 days late. 1 student had $1,429 of federal direct loans returned but then incorrectly disbursed back to the student. These funds were returned back to the Department of Education in September 2024, 247 days late. 1 student had an R2T4 calculated but the unearned funds totaling $5,912 have not yet been returned. 6 students had miscalculations due to Pell not being recalculated for classes the student didn’t begin attendance prior to the R2T4 calculation which resulted in $1,342 of Pell under returned and $463 of federal direct loans (FDL) over returned. 4 students had miscalculations due to incorrect break days used resulting in $9 of Pell and $197 of FDL over returned. Cause: Complexity of R2T4 calculations. Break days not properly factored into the calculation. Pell not properly recalculated prior to the R2T4 calculation for classes students didn't begin attendance in. Effect: Noncompliance with R2T4 regulations Identification as repeat finding, if applicable: 2023-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students’ R2T4 calendars, calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-002
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: The NSLDS enrollment status was not properly reported for some students, primarily those who withdrew from the University. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 77 students tested, 5 students who withdrew were still being reported as enrolled to NSLDS. 2 students were reported as “no record found” but both had federal direct loans disbursed during the year. Cause: The registrar's office was not completing timely reconciliations of enrollment statuses throughout the year. Effect: The incorrect reporting impacts the student's loan grace period, in school deferment eligibility, beginning loans payments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University put a system in place to ensure that students who withdraw either officially or unofficially during a term be checked for proper reporting to NSLDS as part of the R2T4 process. We also recommend that the University is periodically completing reconciliations of enrollment statuses and completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-002
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: The NSLDS enrollment status was not properly reported for some students, primarily those who withdrew from the University. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 77 students tested, 5 students who withdrew were still being reported as enrolled to NSLDS. 2 students were reported as “no record found” but both had federal direct loans disbursed during the year. Cause: The registrar's office was not completing timely reconciliations of enrollment statuses throughout the year. Effect: The incorrect reporting impacts the student's loan grace period, in school deferment eligibility, beginning loans payments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University put a system in place to ensure that students who withdraw either officially or unofficially during a term be checked for proper reporting to NSLDS as part of the R2T4 process. We also recommend that the University is periodically completing reconciliations of enrollment statuses and completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-003
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has made progress from the prior year on GLBA compliance. The University has one remaining area left to implement relating to sufficient vendor management policies and reviews. Cause: The University has prioritized resources to address and document compliance with multi-factor authentication and risk assessment evaluation before implementing the vendor management requirements of GLBA. Effect: The University has not adequately addressed all the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the University allocate sufficient resources to address all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-003
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has made progress from the prior year on GLBA compliance. The University has one remaining area left to implement relating to sufficient vendor management policies and reviews. Cause: The University has prioritized resources to address and document compliance with multi-factor authentication and risk assessment evaluation before implementing the vendor management requirements of GLBA. Effect: The University has not adequately addressed all the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the University allocate sufficient resources to address all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-003
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has made progress from the prior year on GLBA compliance. The University has one remaining area left to implement relating to sufficient vendor management policies and reviews. Cause: The University has prioritized resources to address and document compliance with multi-factor authentication and risk assessment evaluation before implementing the vendor management requirements of GLBA. Effect: The University has not adequately addressed all the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the University allocate sufficient resources to address all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2024-003
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has made progress from the prior year on GLBA compliance. The University has one remaining area left to implement relating to sufficient vendor management policies and reviews. Cause: The University has prioritized resources to address and document compliance with multi-factor authentication and risk assessment evaluation before implementing the vendor management requirements of GLBA. Effect: The University has not adequately addressed all the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the University allocate sufficient resources to address all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.