Finding 2023-001:
Assistance Listing (AL) #84.007 Federal Supplemental Educational Opportunity Grants; AL #84.038 Federal Perkins Loan Program; AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
The University is required to identify official and unofficial withdrawals and perform Return of Title IV calculations (calculations). The University has 30 days after the end of the semester to determine that a student unofficially withdrew. The University then has 45 days from the date it determines the student withdrew to perform the calculations and return the funds to DOE (34 CFR § 668.22(j)).
Condition:
Our audit procedures identified the University did not follow its procedures to return funds to DOE timely. In our sample of twenty-one student withdrawals, four withdrawals (one from Summer 2023, three from Spring 2024) (sample of sixteen, seven withdrawals for the year ended May 31, 2023) did not have funds returned to DOE timely.
Cause:
Staffing shortfalls in the Student Financial Aid (SFA) Office resulted in the reallocation of job duties. Without proper cross training in the SFA Office, the University’s processes for returning funds to DOE were not followed.
Effect:
The University did not perform the calculations, return the required funds, and/or complete the required reporting within the required timeframes.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses staffing needs of the SFA Office to ensure compliance and proper procedures are being followed. These procedures include steps to properly identify all official and unofficial withdrawals and accurately perform calculations within the required timeframes.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals are done monthly going forward.
Finding 2023-001:
Assistance Listing (AL) #84.007 Federal Supplemental Educational Opportunity Grants; AL #84.038 Federal Perkins Loan Program; AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
The University is required to identify official and unofficial withdrawals and perform Return of Title IV calculations (calculations). The University has 30 days after the end of the semester to determine that a student unofficially withdrew. The University then has 45 days from the date it determines the student withdrew to perform the calculations and return the funds to DOE (34 CFR § 668.22(j)).
Condition:
Our audit procedures identified the University did not follow its procedures to return funds to DOE timely. In our sample of twenty-one student withdrawals, four withdrawals (one from Summer 2023, three from Spring 2024) (sample of sixteen, seven withdrawals for the year ended May 31, 2023) did not have funds returned to DOE timely.
Cause:
Staffing shortfalls in the Student Financial Aid (SFA) Office resulted in the reallocation of job duties. Without proper cross training in the SFA Office, the University’s processes for returning funds to DOE were not followed.
Effect:
The University did not perform the calculations, return the required funds, and/or complete the required reporting within the required timeframes.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses staffing needs of the SFA Office to ensure compliance and proper procedures are being followed. These procedures include steps to properly identify all official and unofficial withdrawals and accurately perform calculations within the required timeframes.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals are done monthly going forward.
Finding 2023-001:
Assistance Listing (AL) #84.007 Federal Supplemental Educational Opportunity Grants; AL #84.038 Federal Perkins Loan Program; AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
The University is required to identify official and unofficial withdrawals and perform Return of Title IV calculations (calculations). The University has 30 days after the end of the semester to determine that a student unofficially withdrew. The University then has 45 days from the date it determines the student withdrew to perform the calculations and return the funds to DOE (34 CFR § 668.22(j)).
Condition:
Our audit procedures identified the University did not follow its procedures to return funds to DOE timely. In our sample of twenty-one student withdrawals, four withdrawals (one from Summer 2023, three from Spring 2024) (sample of sixteen, seven withdrawals for the year ended May 31, 2023) did not have funds returned to DOE timely.
Cause:
Staffing shortfalls in the Student Financial Aid (SFA) Office resulted in the reallocation of job duties. Without proper cross training in the SFA Office, the University’s processes for returning funds to DOE were not followed.
Effect:
The University did not perform the calculations, return the required funds, and/or complete the required reporting within the required timeframes.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses staffing needs of the SFA Office to ensure compliance and proper procedures are being followed. These procedures include steps to properly identify all official and unofficial withdrawals and accurately perform calculations within the required timeframes.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals are done monthly going forward.
Finding 2023-001:
Assistance Listing (AL) #84.007 Federal Supplemental Educational Opportunity Grants; AL #84.038 Federal Perkins Loan Program; AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
The University is required to identify official and unofficial withdrawals and perform Return of Title IV calculations (calculations). The University has 30 days after the end of the semester to determine that a student unofficially withdrew. The University then has 45 days from the date it determines the student withdrew to perform the calculations and return the funds to DOE (34 CFR § 668.22(j)).
Condition:
Our audit procedures identified the University did not follow its procedures to return funds to DOE timely. In our sample of twenty-one student withdrawals, four withdrawals (one from Summer 2023, three from Spring 2024) (sample of sixteen, seven withdrawals for the year ended May 31, 2023) did not have funds returned to DOE timely.
Cause:
Staffing shortfalls in the Student Financial Aid (SFA) Office resulted in the reallocation of job duties. Without proper cross training in the SFA Office, the University’s processes for returning funds to DOE were not followed.
Effect:
The University did not perform the calculations, return the required funds, and/or complete the required reporting within the required timeframes.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses staffing needs of the SFA Office to ensure compliance and proper procedures are being followed. These procedures include steps to properly identify all official and unofficial withdrawals and accurately perform calculations within the required timeframes.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals are done monthly going forward.
Finding 2023-002:
AL #84.268 Federal Direct Student Loans
Criteria:
The University is required to provide exit counseling to student borrowers who withdraw or graduate from the University within 30 days of the institution’s knowledge of the exit (34 CFR §685.304(b)).
Condition:
Out of a sample of nine students, our audit procedures identified seven student borrowers who withdrew during the Spring 2024 semester (eleven student borrowers out of a sample of sixteen for the year ended May 31, 2023) that were not provided with the required materials.
Cause:
For students who withdraw, the University currently has procedures in place to attempt exit counseling at the same time funds are returned to the DOE. If the students’ funds are not returned timely, exit counseling is not provided within the 30 day requirement.
Effect:
The University did not provide exit counseling to student borrowers who withdrew from the University within 30 days of the institution’s knowledge of the exit.
Questioned Costs:
None
Auditors’ Recommendation:
The University should update its procedures for providing exit counseling to ensure students receive exit counseling within the timeframe required by the DOE.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward. Additionally, job duties have been reallocated to ensure exit counseling communications are done monthly going forward.
Finding 2024-001:
AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
An institution must submit Pell Grant and Federal Direct Student Loans (FDL) disbursement records to Common Origination and Disbursement (COD), no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement (34 CFR 668.164(a)).
Condition:
Out of a sample of twenty-eight FDL students and forty Pell Grant students, our audit procedures identified the University did not report four FDL and seven Pell Grant disbursements to COD within 15 days of crediting the student billing statements.
Cause:
Automated COD communication and reporting rules in the Student Information System (SIS) were not working properly during the 2023-2024 aid year and manual interventions were not performed in order to report disbursement to COD timely.
Effect:
The University did not complete the required reporting within the required time frames.
Questioned Costs:
None
Auditors’ Recommendation:
The University should update its procedures to include review of automated COD reporting to ensure automated breakdowns are identified and corrected and reporting to COD is done timely.
Views of Responsible Officials:
The University identified certain automated COD communication and reporting rules in the SIS that were not working properly during the 2023-2024 aid year. The breakdown of these automated rules required manual interventions to have all FDL and Pell Grant disbursements reported to COD. Due to significant staffing turnover in the financial aid department and the manual interventions needed, not all reporting was able to be completed within 15 days. In January 2025, the University hired an expert directly from the SIS company to evaluate and fix all malfunctioning rules so manual intervention is not required going forward.
Finding 2024-001:
AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
An institution must submit Pell Grant and Federal Direct Student Loans (FDL) disbursement records to Common Origination and Disbursement (COD), no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement (34 CFR 668.164(a)).
Condition:
Out of a sample of twenty-eight FDL students and forty Pell Grant students, our audit procedures identified the University did not report four FDL and seven Pell Grant disbursements to COD within 15 days of crediting the student billing statements.
Cause:
Automated COD communication and reporting rules in the Student Information System (SIS) were not working properly during the 2023-2024 aid year and manual interventions were not performed in order to report disbursement to COD timely.
Effect:
The University did not complete the required reporting within the required time frames.
Questioned Costs:
None
Auditors’ Recommendation:
The University should update its procedures to include review of automated COD reporting to ensure automated breakdowns are identified and corrected and reporting to COD is done timely.
Views of Responsible Officials:
The University identified certain automated COD communication and reporting rules in the SIS that were not working properly during the 2023-2024 aid year. The breakdown of these automated rules required manual interventions to have all FDL and Pell Grant disbursements reported to COD. Due to significant staffing turnover in the financial aid department and the manual interventions needed, not all reporting was able to be completed within 15 days. In January 2025, the University hired an expert directly from the SIS company to evaluate and fix all malfunctioning rules so manual intervention is not required going forward.
Finding 2024-002: AL #84.268 Federal Direct Student Loans
Criteria:
Under the advanced payment method, the University is required to disburse funds requested from DOE’s grants management system (G5) as soon as administratively feasible but no later than three business days following the date the institution received those funds (34 CFR §688.162(b)(3)).
Condition:
In May 2024, the University withdrew $2,718,000 in FDL from the G5. These funds were not disbursed to students within three business days of receipt and were held by the University until July 2024.
Cause:
The SFA Office experienced processing and student packaging delays from the rollout of the Better Free Application for Federal Student Aid (FAFSA) and related COD updates. This delayed the disbursement of funds to student billing statements.
Effect:
The University did not disburse funds within the required timeframe.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses the staffing needs of the SFA Office to ensure disbursements of student financial aid are done timely and do not exceed immediate need.
Views of Responsible Officials:
The University made an advance funding request in May 2024 for 2024-2025 aid due to severe processing delays related to the rollout of the Better FAFSA and related COD updates. The University’s first Summer 2024 term began on April 1, 2024, with subsequent starts on April 29, 2024, and May 20, 2024. Due to significant difficulties encountered with the Better FAFSA rollout and significant staffing turnover in the financial aid department at that time, the University did not disburse aid and transmit it to COD at the normal rate. This issue was purely timing and was resolved by July 2024.
Finding 2024-003: AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
On a monthly basis, the University is required to reconcile institutional records with the “Student Account Statement” provided by DOE. The University is also required to complete a year-end closeout or final reconciliation of its FDL accounts (34 CFR § 685.300(b)(5)). Although there is no regulatory requirement to reconcile the University’s Pell Grant operations monthly, it is almost impossible to satisfy other program requirements without monthly reconciliation of the University’s Pell Grant participation.
Condition:
The University did not perform monthly and annual FDL and Pell Grant reconciliations.
Cause:
Turnover in the SFA Office resulted in the reallocation of job duties and the University’s process to reconcile the FDL and Pell Grant to go unfollowed.
Effect:
Failure to complete these mandatory reconciliations within the prescribed timelines could result in the inability to finalize the award year on a timely basis. In addition, unreconciled activity could negatively impact a student’s aggregate FDL and Pell Grant limits, resulting in the student becoming ineligible for further aid.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses the staffing needs of the SFA Office to ensure procedures for reconciliation of federal funds are performed timely.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward.
Finding 2024-003: AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
On a monthly basis, the University is required to reconcile institutional records with the “Student Account Statement” provided by DOE. The University is also required to complete a year-end closeout or final reconciliation of its FDL accounts (34 CFR § 685.300(b)(5)). Although there is no regulatory requirement to reconcile the University’s Pell Grant operations monthly, it is almost impossible to satisfy other program requirements without monthly reconciliation of the University’s Pell Grant participation.
Condition:
The University did not perform monthly and annual FDL and Pell Grant reconciliations.
Cause:
Turnover in the SFA Office resulted in the reallocation of job duties and the University’s process to reconcile the FDL and Pell Grant to go unfollowed.
Effect:
Failure to complete these mandatory reconciliations within the prescribed timelines could result in the inability to finalize the award year on a timely basis. In addition, unreconciled activity could negatively impact a student’s aggregate FDL and Pell Grant limits, resulting in the student becoming ineligible for further aid.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses the staffing needs of the SFA Office to ensure procedures for reconciliation of federal funds are performed timely.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward.
Finding 2023-001:
Assistance Listing (AL) #84.007 Federal Supplemental Educational Opportunity Grants; AL #84.038 Federal Perkins Loan Program; AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
The University is required to identify official and unofficial withdrawals and perform Return of Title IV calculations (calculations). The University has 30 days after the end of the semester to determine that a student unofficially withdrew. The University then has 45 days from the date it determines the student withdrew to perform the calculations and return the funds to DOE (34 CFR § 668.22(j)).
Condition:
Our audit procedures identified the University did not follow its procedures to return funds to DOE timely. In our sample of twenty-one student withdrawals, four withdrawals (one from Summer 2023, three from Spring 2024) (sample of sixteen, seven withdrawals for the year ended May 31, 2023) did not have funds returned to DOE timely.
Cause:
Staffing shortfalls in the Student Financial Aid (SFA) Office resulted in the reallocation of job duties. Without proper cross training in the SFA Office, the University’s processes for returning funds to DOE were not followed.
Effect:
The University did not perform the calculations, return the required funds, and/or complete the required reporting within the required timeframes.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses staffing needs of the SFA Office to ensure compliance and proper procedures are being followed. These procedures include steps to properly identify all official and unofficial withdrawals and accurately perform calculations within the required timeframes.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals are done monthly going forward.
Finding 2023-001:
Assistance Listing (AL) #84.007 Federal Supplemental Educational Opportunity Grants; AL #84.038 Federal Perkins Loan Program; AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
The University is required to identify official and unofficial withdrawals and perform Return of Title IV calculations (calculations). The University has 30 days after the end of the semester to determine that a student unofficially withdrew. The University then has 45 days from the date it determines the student withdrew to perform the calculations and return the funds to DOE (34 CFR § 668.22(j)).
Condition:
Our audit procedures identified the University did not follow its procedures to return funds to DOE timely. In our sample of twenty-one student withdrawals, four withdrawals (one from Summer 2023, three from Spring 2024) (sample of sixteen, seven withdrawals for the year ended May 31, 2023) did not have funds returned to DOE timely.
Cause:
Staffing shortfalls in the Student Financial Aid (SFA) Office resulted in the reallocation of job duties. Without proper cross training in the SFA Office, the University’s processes for returning funds to DOE were not followed.
Effect:
The University did not perform the calculations, return the required funds, and/or complete the required reporting within the required timeframes.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses staffing needs of the SFA Office to ensure compliance and proper procedures are being followed. These procedures include steps to properly identify all official and unofficial withdrawals and accurately perform calculations within the required timeframes.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals are done monthly going forward.
Finding 2023-001:
Assistance Listing (AL) #84.007 Federal Supplemental Educational Opportunity Grants; AL #84.038 Federal Perkins Loan Program; AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
The University is required to identify official and unofficial withdrawals and perform Return of Title IV calculations (calculations). The University has 30 days after the end of the semester to determine that a student unofficially withdrew. The University then has 45 days from the date it determines the student withdrew to perform the calculations and return the funds to DOE (34 CFR § 668.22(j)).
Condition:
Our audit procedures identified the University did not follow its procedures to return funds to DOE timely. In our sample of twenty-one student withdrawals, four withdrawals (one from Summer 2023, three from Spring 2024) (sample of sixteen, seven withdrawals for the year ended May 31, 2023) did not have funds returned to DOE timely.
Cause:
Staffing shortfalls in the Student Financial Aid (SFA) Office resulted in the reallocation of job duties. Without proper cross training in the SFA Office, the University’s processes for returning funds to DOE were not followed.
Effect:
The University did not perform the calculations, return the required funds, and/or complete the required reporting within the required timeframes.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses staffing needs of the SFA Office to ensure compliance and proper procedures are being followed. These procedures include steps to properly identify all official and unofficial withdrawals and accurately perform calculations within the required timeframes.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals are done monthly going forward.
Finding 2023-001:
Assistance Listing (AL) #84.007 Federal Supplemental Educational Opportunity Grants; AL #84.038 Federal Perkins Loan Program; AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
The University is required to identify official and unofficial withdrawals and perform Return of Title IV calculations (calculations). The University has 30 days after the end of the semester to determine that a student unofficially withdrew. The University then has 45 days from the date it determines the student withdrew to perform the calculations and return the funds to DOE (34 CFR § 668.22(j)).
Condition:
Our audit procedures identified the University did not follow its procedures to return funds to DOE timely. In our sample of twenty-one student withdrawals, four withdrawals (one from Summer 2023, three from Spring 2024) (sample of sixteen, seven withdrawals for the year ended May 31, 2023) did not have funds returned to DOE timely.
Cause:
Staffing shortfalls in the Student Financial Aid (SFA) Office resulted in the reallocation of job duties. Without proper cross training in the SFA Office, the University’s processes for returning funds to DOE were not followed.
Effect:
The University did not perform the calculations, return the required funds, and/or complete the required reporting within the required timeframes.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses staffing needs of the SFA Office to ensure compliance and proper procedures are being followed. These procedures include steps to properly identify all official and unofficial withdrawals and accurately perform calculations within the required timeframes.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals are done monthly going forward.
Finding 2023-002:
AL #84.268 Federal Direct Student Loans
Criteria:
The University is required to provide exit counseling to student borrowers who withdraw or graduate from the University within 30 days of the institution’s knowledge of the exit (34 CFR §685.304(b)).
Condition:
Out of a sample of nine students, our audit procedures identified seven student borrowers who withdrew during the Spring 2024 semester (eleven student borrowers out of a sample of sixteen for the year ended May 31, 2023) that were not provided with the required materials.
Cause:
For students who withdraw, the University currently has procedures in place to attempt exit counseling at the same time funds are returned to the DOE. If the students’ funds are not returned timely, exit counseling is not provided within the 30 day requirement.
Effect:
The University did not provide exit counseling to student borrowers who withdrew from the University within 30 days of the institution’s knowledge of the exit.
Questioned Costs:
None
Auditors’ Recommendation:
The University should update its procedures for providing exit counseling to ensure students receive exit counseling within the timeframe required by the DOE.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward. Additionally, job duties have been reallocated to ensure exit counseling communications are done monthly going forward.
Finding 2024-001:
AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
An institution must submit Pell Grant and Federal Direct Student Loans (FDL) disbursement records to Common Origination and Disbursement (COD), no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement (34 CFR 668.164(a)).
Condition:
Out of a sample of twenty-eight FDL students and forty Pell Grant students, our audit procedures identified the University did not report four FDL and seven Pell Grant disbursements to COD within 15 days of crediting the student billing statements.
Cause:
Automated COD communication and reporting rules in the Student Information System (SIS) were not working properly during the 2023-2024 aid year and manual interventions were not performed in order to report disbursement to COD timely.
Effect:
The University did not complete the required reporting within the required time frames.
Questioned Costs:
None
Auditors’ Recommendation:
The University should update its procedures to include review of automated COD reporting to ensure automated breakdowns are identified and corrected and reporting to COD is done timely.
Views of Responsible Officials:
The University identified certain automated COD communication and reporting rules in the SIS that were not working properly during the 2023-2024 aid year. The breakdown of these automated rules required manual interventions to have all FDL and Pell Grant disbursements reported to COD. Due to significant staffing turnover in the financial aid department and the manual interventions needed, not all reporting was able to be completed within 15 days. In January 2025, the University hired an expert directly from the SIS company to evaluate and fix all malfunctioning rules so manual intervention is not required going forward.
Finding 2024-001:
AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
An institution must submit Pell Grant and Federal Direct Student Loans (FDL) disbursement records to Common Origination and Disbursement (COD), no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement (34 CFR 668.164(a)).
Condition:
Out of a sample of twenty-eight FDL students and forty Pell Grant students, our audit procedures identified the University did not report four FDL and seven Pell Grant disbursements to COD within 15 days of crediting the student billing statements.
Cause:
Automated COD communication and reporting rules in the Student Information System (SIS) were not working properly during the 2023-2024 aid year and manual interventions were not performed in order to report disbursement to COD timely.
Effect:
The University did not complete the required reporting within the required time frames.
Questioned Costs:
None
Auditors’ Recommendation:
The University should update its procedures to include review of automated COD reporting to ensure automated breakdowns are identified and corrected and reporting to COD is done timely.
Views of Responsible Officials:
The University identified certain automated COD communication and reporting rules in the SIS that were not working properly during the 2023-2024 aid year. The breakdown of these automated rules required manual interventions to have all FDL and Pell Grant disbursements reported to COD. Due to significant staffing turnover in the financial aid department and the manual interventions needed, not all reporting was able to be completed within 15 days. In January 2025, the University hired an expert directly from the SIS company to evaluate and fix all malfunctioning rules so manual intervention is not required going forward.
Finding 2024-002: AL #84.268 Federal Direct Student Loans
Criteria:
Under the advanced payment method, the University is required to disburse funds requested from DOE’s grants management system (G5) as soon as administratively feasible but no later than three business days following the date the institution received those funds (34 CFR §688.162(b)(3)).
Condition:
In May 2024, the University withdrew $2,718,000 in FDL from the G5. These funds were not disbursed to students within three business days of receipt and were held by the University until July 2024.
Cause:
The SFA Office experienced processing and student packaging delays from the rollout of the Better Free Application for Federal Student Aid (FAFSA) and related COD updates. This delayed the disbursement of funds to student billing statements.
Effect:
The University did not disburse funds within the required timeframe.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses the staffing needs of the SFA Office to ensure disbursements of student financial aid are done timely and do not exceed immediate need.
Views of Responsible Officials:
The University made an advance funding request in May 2024 for 2024-2025 aid due to severe processing delays related to the rollout of the Better FAFSA and related COD updates. The University’s first Summer 2024 term began on April 1, 2024, with subsequent starts on April 29, 2024, and May 20, 2024. Due to significant difficulties encountered with the Better FAFSA rollout and significant staffing turnover in the financial aid department at that time, the University did not disburse aid and transmit it to COD at the normal rate. This issue was purely timing and was resolved by July 2024.
Finding 2024-003: AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
On a monthly basis, the University is required to reconcile institutional records with the “Student Account Statement” provided by DOE. The University is also required to complete a year-end closeout or final reconciliation of its FDL accounts (34 CFR § 685.300(b)(5)). Although there is no regulatory requirement to reconcile the University’s Pell Grant operations monthly, it is almost impossible to satisfy other program requirements without monthly reconciliation of the University’s Pell Grant participation.
Condition:
The University did not perform monthly and annual FDL and Pell Grant reconciliations.
Cause:
Turnover in the SFA Office resulted in the reallocation of job duties and the University’s process to reconcile the FDL and Pell Grant to go unfollowed.
Effect:
Failure to complete these mandatory reconciliations within the prescribed timelines could result in the inability to finalize the award year on a timely basis. In addition, unreconciled activity could negatively impact a student’s aggregate FDL and Pell Grant limits, resulting in the student becoming ineligible for further aid.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses the staffing needs of the SFA Office to ensure procedures for reconciliation of federal funds are performed timely.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward.
Finding 2024-003: AL #84.063 Federal Pell Grant Program; AL #84.268 Federal Direct Student Loans
Criteria:
On a monthly basis, the University is required to reconcile institutional records with the “Student Account Statement” provided by DOE. The University is also required to complete a year-end closeout or final reconciliation of its FDL accounts (34 CFR § 685.300(b)(5)). Although there is no regulatory requirement to reconcile the University’s Pell Grant operations monthly, it is almost impossible to satisfy other program requirements without monthly reconciliation of the University’s Pell Grant participation.
Condition:
The University did not perform monthly and annual FDL and Pell Grant reconciliations.
Cause:
Turnover in the SFA Office resulted in the reallocation of job duties and the University’s process to reconcile the FDL and Pell Grant to go unfollowed.
Effect:
Failure to complete these mandatory reconciliations within the prescribed timelines could result in the inability to finalize the award year on a timely basis. In addition, unreconciled activity could negatively impact a student’s aggregate FDL and Pell Grant limits, resulting in the student becoming ineligible for further aid.
Questioned Costs:
None
Auditors’ Recommendation:
The University should provide necessary ongoing cross training as it assesses the staffing needs of the SFA Office to ensure procedures for reconciliation of federal funds are performed timely.
Views of Responsible Officials:
The University experienced staffing turnover in the financial aid department during the 2023- 2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. As of February 2025, the University has established clear roles and responsibilities so established processes are not missed going forward.