U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Cash Management. Condition: Overdrawn federal student aid funds were not timely returned to the Department of Education. Criteria: In accordance with 34 CFR 668.162(b), a school may not request more funds than the school needs immediately related to the disbursements the school has made or will make to eligible students and parents. A school must make the disbursements as soon as administratively feasible, but no later than three business days following the date the school receives those funds. Any funds not disbursed by the end of the third business day are considered excess cash. Cause: Lack of controls over cash management. Effect: Excess federal cash retained by the institution. Context: The University had overdrawn federal student aid funds of approximately $219,000 at June 30, 2024 related to draws that were made during June 2024. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend the University implement appropriate training regarding compliance regulations into the employee onboarding process and thereafter for applicable employees. Additionally, we recommend the University implements timely review procedures to ensure that any overdrawn funds are returned within the tolerance period.
U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Return of Title IV Funds (Significant Deficiency). Condition: The University failed to return Title VI funds to the Department of Education within 45 days of student’s date of determination. Criteria: Return of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR Section 668.173(b). Cause: Controls are not functioning properly. Effect: Funds were not timely returned to students or federal agencies as required. Context: From a population of 129 students that withdrew officially or unofficially during a term, we tested 12 students and noted that the R2T4 calculations were required for nine students. Of the nine students, R2T4 calculations were prepared untimely for six students, resulting in a late return of Title IV funds. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend procedures are put in place to ensure R2T4 calculations are performed timely following the University’s date of determination.
U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Enrollment Reporting (Significant Deficiency). Condition: The University did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: Based on requirements set forth by 34 CFR Section 685.309(b)(2), the University is responsible for notifying the National Student Loan Data System (NSLDS) of changes to student’s enrollment data within minimum required timeframes. Cause: Controls are not functioning properly. Effect: Enrollment data was not reported timely or accurately to the Department of Education thus, the Department could not properly service the student’s loans. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Context: From a population of 129 students that withdrew officially or unofficially during a term, we tested 12 students and noted that the withdrawal date was incorrectly reported as the last day of the term for four students and was not reported for one student. In addition, the R2T4 calculation was prepared untimely for four students that required a calculation, as noted in finding 2024-004, and thus the withdrawal dates were reported untimely. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend that a review process be put in place to ensure timely and accurate enrollment reporting to NSLDS.
U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Cash Management. Condition: Overdrawn federal student aid funds were not timely returned to the Department of Education. Criteria: In accordance with 34 CFR 668.162(b), a school may not request more funds than the school needs immediately related to the disbursements the school has made or will make to eligible students and parents. A school must make the disbursements as soon as administratively feasible, but no later than three business days following the date the school receives those funds. Any funds not disbursed by the end of the third business day are considered excess cash. Cause: Lack of controls over cash management. Effect: Excess federal cash retained by the institution. Context: The University had overdrawn federal student aid funds of approximately $219,000 at June 30, 2024 related to draws that were made during June 2024. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend the University implement appropriate training regarding compliance regulations into the employee onboarding process and thereafter for applicable employees. Additionally, we recommend the University implements timely review procedures to ensure that any overdrawn funds are returned within the tolerance period.
U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Return of Title IV Funds (Significant Deficiency). Condition: The University failed to return Title VI funds to the Department of Education within 45 days of student’s date of determination. Criteria: Return of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR Section 668.173(b). Cause: Controls are not functioning properly. Effect: Funds were not timely returned to students or federal agencies as required. Context: From a population of 129 students that withdrew officially or unofficially during a term, we tested 12 students and noted that the R2T4 calculations were required for nine students. Of the nine students, R2T4 calculations were prepared untimely for six students, resulting in a late return of Title IV funds. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend procedures are put in place to ensure R2T4 calculations are performed timely following the University’s date of determination.
U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Enrollment Reporting (Significant Deficiency). Condition: The University did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: Based on requirements set forth by 34 CFR Section 685.309(b)(2), the University is responsible for notifying the National Student Loan Data System (NSLDS) of changes to student’s enrollment data within minimum required timeframes. Cause: Controls are not functioning properly. Effect: Enrollment data was not reported timely or accurately to the Department of Education thus, the Department could not properly service the student’s loans. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Context: From a population of 129 students that withdrew officially or unofficially during a term, we tested 12 students and noted that the withdrawal date was incorrectly reported as the last day of the term for four students and was not reported for one student. In addition, the R2T4 calculation was prepared untimely for four students that required a calculation, as noted in finding 2024-004, and thus the withdrawal dates were reported untimely. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend that a review process be put in place to ensure timely and accurate enrollment reporting to NSLDS.