2024 - 001 – Student Credit Balances
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, that whenever an institution disburses Title IV funds by crediting a student's account and the total amount of all Title IV funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but—
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Three student credit balances were not refunded within the required 14-day time frame.
Questioned Costs: None.
Context: During our testing, 3 students out of a sample of 40 had a credit balance as a result of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund a student within 14 days for a credit balance that arose from federal funds as required by Department of Education regulations.
Repeat Finding: Yes, 2023-001. Auditors’ Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe.
Views of Responsible Officials: Management agrees with the finding.
2024 - 001 – Student Credit Balances
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, that whenever an institution disburses Title IV funds by crediting a student's account and the total amount of all Title IV funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but—
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Three student credit balances were not refunded within the required 14-day time frame.
Questioned Costs: None.
Context: During our testing, 3 students out of a sample of 40 had a credit balance as a result of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund a student within 14 days for a credit balance that arose from federal funds as required by Department of Education regulations.
Repeat Finding: Yes, 2023-001. Auditors’ Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe.
Views of Responsible Officials: Management agrees with the finding.
2024 - 001 – Student Credit Balances
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, that whenever an institution disburses Title IV funds by crediting a student's account and the total amount of all Title IV funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but—
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Three student credit balances were not refunded within the required 14-day time frame.
Questioned Costs: None.
Context: During our testing, 3 students out of a sample of 40 had a credit balance as a result of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund a student within 14 days for a credit balance that arose from federal funds as required by Department of Education regulations.
Repeat Finding: Yes, 2023-001. Auditors’ Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe.
Views of Responsible Officials: Management agrees with the finding.
2024 - 001 – Student Credit Balances
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, that whenever an institution disburses Title IV funds by crediting a student's account and the total amount of all Title IV funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but—
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Three student credit balances were not refunded within the required 14-day time frame.
Questioned Costs: None.
Context: During our testing, 3 students out of a sample of 40 had a credit balance as a result of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund a student within 14 days for a credit balance that arose from federal funds as required by Department of Education regulations.
Repeat Finding: Yes, 2023-001. Auditors’ Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe.
Views of Responsible Officials: Management agrees with the finding.
2024 - 001 – Student Credit Balances
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, that whenever an institution disburses Title IV funds by crediting a student's account and the total amount of all Title IV funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but—
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Three student credit balances were not refunded within the required 14-day time frame.
Questioned Costs: None.
Context: During our testing, 3 students out of a sample of 40 had a credit balance as a result of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund a student within 14 days for a credit balance that arose from federal funds as required by Department of Education regulations.
Repeat Finding: Yes, 2023-001. Auditors’ Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe.
Views of Responsible Officials: Management agrees with the finding.
2024 – 002 – National Student Loan Data System (NSLDS) Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610).
Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following out of our sample of 40 students tested:
• 3 students had effective dates at the campus and program level that did not agree between the University’s records and the NSLDS
• 8 students were not reported to the campus level record in NSLDS in a timely manner. At a minimum, schools are required to certify enrollment every 60 days.
• 1 student was never reported to NSLDS.
Cause: The University’s process in place for timely reporting and updating effective dates within the Banner system were not functioning properly.
Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations.
Views of responsible officials: Management agrees with the finding.
2024 - 003 – Perkins Loan Recordkeeping and Record Retention
Federal Agency: U.S. Department of Education
Federal Program Title: Federal Perkins Loan Program
Federal Assistance Listing Number: 84.038
Award Period: 6/1/23 –5/31/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement: An institution shall keep original promissory notes and repayment schedules until Perkins loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. An institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container (34 CFR 674.19(e)(4)).
Condition: Original promissory notes were unable to be located.
Questioned costs: None. Context: During our testing, we noted 6 instances out of 40 retired/assigned loans where the University was unable to locate the original promissory note.
Cause: The University did not have the appropriate policies and procedures in place when Perkins loans were awarded to students to ensure that recordkeeping and retention regulations were being followed.
Effect: Open loan balances for these loans are not supported by an original promissory note.
Repeat finding: Yes, 2023-003.
Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention.
Views of responsible officials: Management agrees with the finding.
2024 - 004 – Title IV Outstanding Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days not returned to the Department of Ed.
Questioned costs: $5,420
Context: During our testing, we noted 5 Title IV checks outstanding over 240 days that were not returned to the Department of Education.
Cause: The University did not have a process in place to ensure Title IV checks outstanding more than 240 days were returned within the required timeframe.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Recommendation: We recommend the University review its policies and procedures related to outstanding Title IV checks to ensure they are being returned to the Department of Education after being outstanding more than 240 days.
Views of responsible officials: Management agrees with the finding.
2024 - 004 – Title IV Outstanding Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days not returned to the Department of Ed.
Questioned costs: $5,420
Context: During our testing, we noted 5 Title IV checks outstanding over 240 days that were not returned to the Department of Education.
Cause: The University did not have a process in place to ensure Title IV checks outstanding more than 240 days were returned within the required timeframe.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Recommendation: We recommend the University review its policies and procedures related to outstanding Title IV checks to ensure they are being returned to the Department of Education after being outstanding more than 240 days.
Views of responsible officials: Management agrees with the finding.
2024 - 004 – Title IV Outstanding Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days not returned to the Department of Ed.
Questioned costs: $5,420
Context: During our testing, we noted 5 Title IV checks outstanding over 240 days that were not returned to the Department of Education.
Cause: The University did not have a process in place to ensure Title IV checks outstanding more than 240 days were returned within the required timeframe.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Recommendation: We recommend the University review its policies and procedures related to outstanding Title IV checks to ensure they are being returned to the Department of Education after being outstanding more than 240 days.
Views of responsible officials: Management agrees with the finding.
2024 - 004 – Title IV Outstanding Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days not returned to the Department of Ed.
Questioned costs: $5,420
Context: During our testing, we noted 5 Title IV checks outstanding over 240 days that were not returned to the Department of Education.
Cause: The University did not have a process in place to ensure Title IV checks outstanding more than 240 days were returned within the required timeframe.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Recommendation: We recommend the University review its policies and procedures related to outstanding Title IV checks to ensure they are being returned to the Department of Education after being outstanding more than 240 days.
Views of responsible officials: Management agrees with the finding.
2024 - 001 – Student Credit Balances
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, that whenever an institution disburses Title IV funds by crediting a student's account and the total amount of all Title IV funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but—
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Three student credit balances were not refunded within the required 14-day time frame.
Questioned Costs: None.
Context: During our testing, 3 students out of a sample of 40 had a credit balance as a result of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund a student within 14 days for a credit balance that arose from federal funds as required by Department of Education regulations.
Repeat Finding: Yes, 2023-001. Auditors’ Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe.
Views of Responsible Officials: Management agrees with the finding.
2024 - 001 – Student Credit Balances
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, that whenever an institution disburses Title IV funds by crediting a student's account and the total amount of all Title IV funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but—
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Three student credit balances were not refunded within the required 14-day time frame.
Questioned Costs: None.
Context: During our testing, 3 students out of a sample of 40 had a credit balance as a result of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund a student within 14 days for a credit balance that arose from federal funds as required by Department of Education regulations.
Repeat Finding: Yes, 2023-001. Auditors’ Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe.
Views of Responsible Officials: Management agrees with the finding.
2024 - 001 – Student Credit Balances
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, that whenever an institution disburses Title IV funds by crediting a student's account and the total amount of all Title IV funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but—
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Three student credit balances were not refunded within the required 14-day time frame.
Questioned Costs: None.
Context: During our testing, 3 students out of a sample of 40 had a credit balance as a result of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund a student within 14 days for a credit balance that arose from federal funds as required by Department of Education regulations.
Repeat Finding: Yes, 2023-001. Auditors’ Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe.
Views of Responsible Officials: Management agrees with the finding.
2024 - 001 – Student Credit Balances
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, that whenever an institution disburses Title IV funds by crediting a student's account and the total amount of all Title IV funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but—
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Three student credit balances were not refunded within the required 14-day time frame.
Questioned Costs: None.
Context: During our testing, 3 students out of a sample of 40 had a credit balance as a result of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund a student within 14 days for a credit balance that arose from federal funds as required by Department of Education regulations.
Repeat Finding: Yes, 2023-001. Auditors’ Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe.
Views of Responsible Officials: Management agrees with the finding.
2024 - 001 – Student Credit Balances
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, that whenever an institution disburses Title IV funds by crediting a student's account and the total amount of all Title IV funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but—
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: Three student credit balances were not refunded within the required 14-day time frame.
Questioned Costs: None.
Context: During our testing, 3 students out of a sample of 40 had a credit balance as a result of receiving Title IV aid that was not returned within the required 14-day timeframe.
Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly.
Effect: The University did not refund a student within 14 days for a credit balance that arose from federal funds as required by Department of Education regulations.
Repeat Finding: Yes, 2023-001. Auditors’ Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe.
Views of Responsible Officials: Management agrees with the finding.
2024 – 002 – National Student Loan Data System (NSLDS) Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610).
Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following out of our sample of 40 students tested:
• 3 students had effective dates at the campus and program level that did not agree between the University’s records and the NSLDS
• 8 students were not reported to the campus level record in NSLDS in a timely manner. At a minimum, schools are required to certify enrollment every 60 days.
• 1 student was never reported to NSLDS.
Cause: The University’s process in place for timely reporting and updating effective dates within the Banner system were not functioning properly.
Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations.
Views of responsible officials: Management agrees with the finding.
2024 - 003 – Perkins Loan Recordkeeping and Record Retention
Federal Agency: U.S. Department of Education
Federal Program Title: Federal Perkins Loan Program
Federal Assistance Listing Number: 84.038
Award Period: 6/1/23 –5/31/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement: An institution shall keep original promissory notes and repayment schedules until Perkins loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. An institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container (34 CFR 674.19(e)(4)).
Condition: Original promissory notes were unable to be located.
Questioned costs: None. Context: During our testing, we noted 6 instances out of 40 retired/assigned loans where the University was unable to locate the original promissory note.
Cause: The University did not have the appropriate policies and procedures in place when Perkins loans were awarded to students to ensure that recordkeeping and retention regulations were being followed.
Effect: Open loan balances for these loans are not supported by an original promissory note.
Repeat finding: Yes, 2023-003.
Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention.
Views of responsible officials: Management agrees with the finding.
2024 - 004 – Title IV Outstanding Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days not returned to the Department of Ed.
Questioned costs: $5,420
Context: During our testing, we noted 5 Title IV checks outstanding over 240 days that were not returned to the Department of Education.
Cause: The University did not have a process in place to ensure Title IV checks outstanding more than 240 days were returned within the required timeframe.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Recommendation: We recommend the University review its policies and procedures related to outstanding Title IV checks to ensure they are being returned to the Department of Education after being outstanding more than 240 days.
Views of responsible officials: Management agrees with the finding.
2024 - 004 – Title IV Outstanding Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days not returned to the Department of Ed.
Questioned costs: $5,420
Context: During our testing, we noted 5 Title IV checks outstanding over 240 days that were not returned to the Department of Education.
Cause: The University did not have a process in place to ensure Title IV checks outstanding more than 240 days were returned within the required timeframe.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Recommendation: We recommend the University review its policies and procedures related to outstanding Title IV checks to ensure they are being returned to the Department of Education after being outstanding more than 240 days.
Views of responsible officials: Management agrees with the finding.
2024 - 004 – Title IV Outstanding Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days not returned to the Department of Ed.
Questioned costs: $5,420
Context: During our testing, we noted 5 Title IV checks outstanding over 240 days that were not returned to the Department of Education.
Cause: The University did not have a process in place to ensure Title IV checks outstanding more than 240 days were returned within the required timeframe.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Recommendation: We recommend the University review its policies and procedures related to outstanding Title IV checks to ensure they are being returned to the Department of Education after being outstanding more than 240 days.
Views of responsible officials: Management agrees with the finding.
2024 - 004 – Title IV Outstanding Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Period: 7/1/23-6/30/24
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days not returned to the Department of Ed.
Questioned costs: $5,420
Context: During our testing, we noted 5 Title IV checks outstanding over 240 days that were not returned to the Department of Education.
Cause: The University did not have a process in place to ensure Title IV checks outstanding more than 240 days were returned within the required timeframe.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education.
Recommendation: We recommend the University review its policies and procedures related to outstanding Title IV checks to ensure they are being returned to the Department of Education after being outstanding more than 240 days.
Views of responsible officials: Management agrees with the finding.