Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions, Subpart E, Verification and Updating of Student Aid Application Information, (34 CFR 668) section 53(a) states an institution must establish and use written policies and procedures for verifying an applicant’s FAFSA information in accordance with the provisions. Section 53(c) states an institutions procedure must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the Higher Education Act (HEA) to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the expected family contribution (EFC). The Central Processing System (CPS) selects which applications are to be verified, but institutions have the authority to verify additional students. Institutions must report the verification results for any student whom the institution (1) received an ISIR with tracking flag V4 or V5 as selected by CPS and (2) requested verification documentation. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students selected for verification totaling $626,831 of disbursed title IV funds, we noted the following: • The US income taxes paid – parent and Education tax credits – parent reported to CPS for a V1 verification (totaling $10,667 of disbursed title IV funds) for one student was not accurate. The identity / statement of education purpose was not reported to CPS for V4/V5 verification (totaling $363,813 of disbursed title IV funds) for twenty-one students. Upon further review by the University, all of the V4/V5 students selected by CPS, a total of 130 students, (totaling $2,425,028 of disbursed title IV funds) did not have the identity / statement of education purpose submitted to the CPS during fiscal year 2024. Further, we noted the University did not have adequate controls in place to ensure that V1 and V4/V5 verification data was reported to the CPS. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues contributed to the inaccurate V1 submission and V4/V5 verifications not being submitted to the CPS. Possible Asserted Effect: Failure to accurately and completely submit student verification information to the CPS could result in Title IV funds being awarded and disbursed to student’s that are not eligible. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University strengthen processes and internal controls to ensure the University has effective internal controls in place to ensure verification are being completely and accurately submitted to the CPS. View of Responsible Official: We agree with the findings outlined in the audit report. Historically, the University has maintained strong compliance with verification requirements, and we are confident that these issues are isolated occurrences. To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students’ eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions, Subpart E, Verification and Updating of Student Aid Application Information, (34 CFR 668) section 53(a) states an institution must establish and use written policies and procedures for verifying an applicant’s FAFSA information in accordance with the provisions. Section 53(c) states an institutions procedure must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the Higher Education Act (HEA) to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the expected family contribution (EFC). The Central Processing System (CPS) selects which applications are to be verified, but institutions have the authority to verify additional students. Institutions must report the verification results for any student whom the institution (1) received an ISIR with tracking flag V4 or V5 as selected by CPS and (2) requested verification documentation. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students selected for verification totaling $626,831 of disbursed title IV funds, we noted the following: • The US income taxes paid – parent and Education tax credits – parent reported to CPS for a V1 verification (totaling $10,667 of disbursed title IV funds) for one student was not accurate. The identity / statement of education purpose was not reported to CPS for V4/V5 verification (totaling $363,813 of disbursed title IV funds) for twenty-one students. Upon further review by the University, all of the V4/V5 students selected by CPS, a total of 130 students, (totaling $2,425,028 of disbursed title IV funds) did not have the identity / statement of education purpose submitted to the CPS during fiscal year 2024. Further, we noted the University did not have adequate controls in place to ensure that V1 and V4/V5 verification data was reported to the CPS. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues contributed to the inaccurate V1 submission and V4/V5 verifications not being submitted to the CPS. Possible Asserted Effect: Failure to accurately and completely submit student verification information to the CPS could result in Title IV funds being awarded and disbursed to student’s that are not eligible. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University strengthen processes and internal controls to ensure the University has effective internal controls in place to ensure verification are being completely and accurately submitted to the CPS. View of Responsible Official: We agree with the findings outlined in the audit report. Historically, the University has maintained strong compliance with verification requirements, and we are confident that these issues are isolated occurrences. To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students’ eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions, Subpart E, Verification and Updating of Student Aid Application Information, (34 CFR 668) section 53(a) states an institution must establish and use written policies and procedures for verifying an applicant’s FAFSA information in accordance with the provisions. Section 53(c) states an institutions procedure must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the Higher Education Act (HEA) to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the expected family contribution (EFC). The Central Processing System (CPS) selects which applications are to be verified, but institutions have the authority to verify additional students. Institutions must report the verification results for any student whom the institution (1) received an ISIR with tracking flag V4 or V5 as selected by CPS and (2) requested verification documentation. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students selected for verification totaling $626,831 of disbursed title IV funds, we noted the following: • The US income taxes paid – parent and Education tax credits – parent reported to CPS for a V1 verification (totaling $10,667 of disbursed title IV funds) for one student was not accurate. The identity / statement of education purpose was not reported to CPS for V4/V5 verification (totaling $363,813 of disbursed title IV funds) for twenty-one students. Upon further review by the University, all of the V4/V5 students selected by CPS, a total of 130 students, (totaling $2,425,028 of disbursed title IV funds) did not have the identity / statement of education purpose submitted to the CPS during fiscal year 2024. Further, we noted the University did not have adequate controls in place to ensure that V1 and V4/V5 verification data was reported to the CPS. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues contributed to the inaccurate V1 submission and V4/V5 verifications not being submitted to the CPS. Possible Asserted Effect: Failure to accurately and completely submit student verification information to the CPS could result in Title IV funds being awarded and disbursed to student’s that are not eligible. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University strengthen processes and internal controls to ensure the University has effective internal controls in place to ensure verification are being completely and accurately submitted to the CPS. View of Responsible Official: We agree with the findings outlined in the audit report. Historically, the University has maintained strong compliance with verification requirements, and we are confident that these issues are isolated occurrences. To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students’ eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions, Subpart E, Verification and Updating of Student Aid Application Information, (34 CFR 668) section 53(a) states an institution must establish and use written policies and procedures for verifying an applicant’s FAFSA information in accordance with the provisions. Section 53(c) states an institutions procedure must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the Higher Education Act (HEA) to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the expected family contribution (EFC). The Central Processing System (CPS) selects which applications are to be verified, but institutions have the authority to verify additional students. Institutions must report the verification results for any student whom the institution (1) received an ISIR with tracking flag V4 or V5 as selected by CPS and (2) requested verification documentation. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students selected for verification totaling $626,831 of disbursed title IV funds, we noted the following: • The US income taxes paid – parent and Education tax credits – parent reported to CPS for a V1 verification (totaling $10,667 of disbursed title IV funds) for one student was not accurate. The identity / statement of education purpose was not reported to CPS for V4/V5 verification (totaling $363,813 of disbursed title IV funds) for twenty-one students. Upon further review by the University, all of the V4/V5 students selected by CPS, a total of 130 students, (totaling $2,425,028 of disbursed title IV funds) did not have the identity / statement of education purpose submitted to the CPS during fiscal year 2024. Further, we noted the University did not have adequate controls in place to ensure that V1 and V4/V5 verification data was reported to the CPS. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues contributed to the inaccurate V1 submission and V4/V5 verifications not being submitted to the CPS. Possible Asserted Effect: Failure to accurately and completely submit student verification information to the CPS could result in Title IV funds being awarded and disbursed to student’s that are not eligible. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University strengthen processes and internal controls to ensure the University has effective internal controls in place to ensure verification are being completely and accurately submitted to the CPS. View of Responsible Official: We agree with the findings outlined in the audit report. Historically, the University has maintained strong compliance with verification requirements, and we are confident that these issues are isolated occurrences. To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students’ eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions, Subpart E, Verification and Updating of Student Aid Application Information, (34 CFR 668) section 53(a) states an institution must establish and use written policies and procedures for verifying an applicant’s FAFSA information in accordance with the provisions. Section 53(c) states an institutions procedure must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the Higher Education Act (HEA) to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the expected family contribution (EFC). The Central Processing System (CPS) selects which applications are to be verified, but institutions have the authority to verify additional students. Institutions must report the verification results for any student whom the institution (1) received an ISIR with tracking flag V4 or V5 as selected by CPS and (2) requested verification documentation. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students selected for verification totaling $626,831 of disbursed title IV funds, we noted the following: • The US income taxes paid – parent and Education tax credits – parent reported to CPS for a V1 verification (totaling $10,667 of disbursed title IV funds) for one student was not accurate. The identity / statement of education purpose was not reported to CPS for V4/V5 verification (totaling $363,813 of disbursed title IV funds) for twenty-one students. Upon further review by the University, all of the V4/V5 students selected by CPS, a total of 130 students, (totaling $2,425,028 of disbursed title IV funds) did not have the identity / statement of education purpose submitted to the CPS during fiscal year 2024. Further, we noted the University did not have adequate controls in place to ensure that V1 and V4/V5 verification data was reported to the CPS. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues contributed to the inaccurate V1 submission and V4/V5 verifications not being submitted to the CPS. Possible Asserted Effect: Failure to accurately and completely submit student verification information to the CPS could result in Title IV funds being awarded and disbursed to student’s that are not eligible. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University strengthen processes and internal controls to ensure the University has effective internal controls in place to ensure verification are being completely and accurately submitted to the CPS. View of Responsible Official: We agree with the findings outlined in the audit report. Historically, the University has maintained strong compliance with verification requirements, and we are confident that these issues are isolated occurrences. To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students’ eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions (34 CFR 668) section 165(a) states that before an institution disburses title IV, Higher Education Act of 1965, as amended (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parents can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted the University did not have appropriate monitoring controls in place to ensure the University sent required award notifications to students prior to title IV funds being accepted and disbursed. During our testing of 52 student disbursements under the FDL program totaling $151,584, we noted the University did not send an award letter notification to 2 students (with loan disbursements of $6,213) and sent an award letter notification subsequent to the first disbursement of the award year for 4 students (with loan disbursements of $23,748). Management performed a review comparing the date of all award notifications sent to Direct Loan borrowers during fiscal year 2024 to the date of Direct Loan disbursements made by the University. Management's review identified 190 (3.6% of the population) Direct Loan award notifications submitted to Direct Loan borrowers subsequent to the date of the Direct Loan disbursement out of 5,237 total Direct Loan disbursements made during fiscal year 2024. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues resulted in award notifications not being sent to students prior to disbursement. Possible Asserted Effect: Failure to notify a parent or student of the anticipated award awarded for the fiscal year results in oncompliance with FDL program requirements. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its system of internal control to ensure award notifications are made as required by FDL program regulations. View of Responsible Official: We acknowledge the finding regarding award notifications being sent to students after Title IV Direct Loan funds were disbursed in certain instances during the audit period. While the instances noted represent a small percentage of our total population (3.6%), we take compliance with federal regulations seriously and are committed to ensuring all required notifications are provided in a timely manner. The issue arose due to occasional manual intervention by staff to expedite disbursements for the benefit of students, such as addressing urgent financial needs, which moved faster than our automated system’s weekly aid offer notification process. Our current operational capacity limits the frequency of aid offer notifications to once per week, which created a gap when disbursements were accelerated manually.We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. We have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions (34 CFR 668) section 165(a) states that before an institution disburses title IV, Higher Education Act of 1965, as amended (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parents can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted the University did not have appropriate monitoring controls in place to ensure the University sent required award notifications to students prior to title IV funds being accepted and disbursed. During our testing of 52 student disbursements under the FDL program totaling $151,584, we noted the University did not send an award letter notification to 2 students (with loan disbursements of $6,213) and sent an award letter notification subsequent to the first disbursement of the award year for 4 students (with loan disbursements of $23,748). Management performed a review comparing the date of all award notifications sent to Direct Loan borrowers during fiscal year 2024 to the date of Direct Loan disbursements made by the University. Management's review identified 190 (3.6% of the population) Direct Loan award notifications submitted to Direct Loan borrowers subsequent to the date of the Direct Loan disbursement out of 5,237 total Direct Loan disbursements made during fiscal year 2024. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues resulted in award notifications not being sent to students prior to disbursement. Possible Asserted Effect: Failure to notify a parent or student of the anticipated award awarded for the fiscal year results in oncompliance with FDL program requirements. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its system of internal control to ensure award notifications are made as required by FDL program regulations. View of Responsible Official: We acknowledge the finding regarding award notifications being sent to students after Title IV Direct Loan funds were disbursed in certain instances during the audit period. While the instances noted represent a small percentage of our total population (3.6%), we take compliance with federal regulations seriously and are committed to ensuring all required notifications are provided in a timely manner. The issue arose due to occasional manual intervention by staff to expedite disbursements for the benefit of students, such as addressing urgent financial needs, which moved faster than our automated system’s weekly aid offer notification process. Our current operational capacity limits the frequency of aid offer notifications to once per week, which created a gap when disbursements were accelerated manually.We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. We have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions (34 CFR 668) section 165(a) states that before an institution disburses title IV, Higher Education Act of 1965, as amended (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parents can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted the University did not have appropriate monitoring controls in place to ensure the University sent required award notifications to students prior to title IV funds being accepted and disbursed. During our testing of 52 student disbursements under the FDL program totaling $151,584, we noted the University did not send an award letter notification to 2 students (with loan disbursements of $6,213) and sent an award letter notification subsequent to the first disbursement of the award year for 4 students (with loan disbursements of $23,748). Management performed a review comparing the date of all award notifications sent to Direct Loan borrowers during fiscal year 2024 to the date of Direct Loan disbursements made by the University. Management's review identified 190 (3.6% of the population) Direct Loan award notifications submitted to Direct Loan borrowers subsequent to the date of the Direct Loan disbursement out of 5,237 total Direct Loan disbursements made during fiscal year 2024. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues resulted in award notifications not being sent to students prior to disbursement. Possible Asserted Effect: Failure to notify a parent or student of the anticipated award awarded for the fiscal year results in oncompliance with FDL program requirements. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its system of internal control to ensure award notifications are made as required by FDL program regulations. View of Responsible Official: We acknowledge the finding regarding award notifications being sent to students after Title IV Direct Loan funds were disbursed in certain instances during the audit period. While the instances noted represent a small percentage of our total population (3.6%), we take compliance with federal regulations seriously and are committed to ensuring all required notifications are provided in a timely manner. The issue arose due to occasional manual intervention by staff to expedite disbursements for the benefit of students, such as addressing urgent financial needs, which moved faster than our automated system’s weekly aid offer notification process. Our current operational capacity limits the frequency of aid offer notifications to once per week, which created a gap when disbursements were accelerated manually.We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. We have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions (34 CFR 668) section 165(a) states that before an institution disburses title IV, Higher Education Act of 1965, as amended (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parents can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted the University did not have appropriate monitoring controls in place to ensure the University sent required award notifications to students prior to title IV funds being accepted and disbursed. During our testing of 52 student disbursements under the FDL program totaling $151,584, we noted the University did not send an award letter notification to 2 students (with loan disbursements of $6,213) and sent an award letter notification subsequent to the first disbursement of the award year for 4 students (with loan disbursements of $23,748). Management performed a review comparing the date of all award notifications sent to Direct Loan borrowers during fiscal year 2024 to the date of Direct Loan disbursements made by the University. Management's review identified 190 (3.6% of the population) Direct Loan award notifications submitted to Direct Loan borrowers subsequent to the date of the Direct Loan disbursement out of 5,237 total Direct Loan disbursements made during fiscal year 2024. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues resulted in award notifications not being sent to students prior to disbursement. Possible Asserted Effect: Failure to notify a parent or student of the anticipated award awarded for the fiscal year results in oncompliance with FDL program requirements. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its system of internal control to ensure award notifications are made as required by FDL program regulations. View of Responsible Official: We acknowledge the finding regarding award notifications being sent to students after Title IV Direct Loan funds were disbursed in certain instances during the audit period. While the instances noted represent a small percentage of our total population (3.6%), we take compliance with federal regulations seriously and are committed to ensuring all required notifications are provided in a timely manner. The issue arose due to occasional manual intervention by staff to expedite disbursements for the benefit of students, such as addressing urgent financial needs, which moved faster than our automated system’s weekly aid offer notification process. Our current operational capacity limits the frequency of aid offer notifications to once per week, which created a gap when disbursements were accelerated manually.We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. We have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions (34 CFR 668) section 165(a) states that before an institution disburses title IV, Higher Education Act of 1965, as amended (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parents can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted the University did not have appropriate monitoring controls in place to ensure the University sent required award notifications to students prior to title IV funds being accepted and disbursed. During our testing of 52 student disbursements under the FDL program totaling $151,584, we noted the University did not send an award letter notification to 2 students (with loan disbursements of $6,213) and sent an award letter notification subsequent to the first disbursement of the award year for 4 students (with loan disbursements of $23,748). Management performed a review comparing the date of all award notifications sent to Direct Loan borrowers during fiscal year 2024 to the date of Direct Loan disbursements made by the University. Management's review identified 190 (3.6% of the population) Direct Loan award notifications submitted to Direct Loan borrowers subsequent to the date of the Direct Loan disbursement out of 5,237 total Direct Loan disbursements made during fiscal year 2024. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues resulted in award notifications not being sent to students prior to disbursement. Possible Asserted Effect: Failure to notify a parent or student of the anticipated award awarded for the fiscal year results in oncompliance with FDL program requirements. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its system of internal control to ensure award notifications are made as required by FDL program regulations. View of Responsible Official: We acknowledge the finding regarding award notifications being sent to students after Title IV Direct Loan funds were disbursed in certain instances during the audit period. While the instances noted represent a small percentage of our total population (3.6%), we take compliance with federal regulations seriously and are committed to ensuring all required notifications are provided in a timely manner. The issue arose due to occasional manual intervention by staff to expedite disbursements for the benefit of students, such as addressing urgent financial needs, which moved faster than our automated system’s weekly aid offer notification process. Our current operational capacity limits the frequency of aid offer notifications to once per week, which created a gap when disbursements were accelerated manually.We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. We have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per OMB No. 1845-0039, an institution is required to submit Pell disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. In accordance with Volume 4, Chapter 2 of the Federal Student Aid Handbook, an institution must submit Direct Loan and Pell Grant disbursement records to the COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 52 students under the Federal Direct Loan (FDL) program totaling $151,584, we noted the following: · The academic end date reported to the COD for FDL disbursements (totaling $46,717) to 4 students was not accurate. Specifically, the date reported was 2 to 5 days later than the actual academic end date. · The student year reported to the COD for FDL disbursements (totaling $8,933) to 1 student was not accurate. Specifically, the academic year reported was year 2 when the actual academic year was year 1. · The FDL disbursements (totaling $11,313) to 2 students was not reported to the COD within the 15 days as required. During our testwork of 8 students under the Pell program totaling $17,469 we noted the following: · The Pell disbursements (totaling $6,138) to 4 students was not reported to the COD within 15 days as required. Management performed a comparison of all disbursements of FDL and Pell during fiscal year 2024 compared to the reporting to the COD. This report shows noncompliance of 1,539 Pell disbursements submitted late as of July 22, 2024, out of 4,634 total Pell disbursements (33% of population) and 193 FDL disbursements submitted late or not submitted as of July 22, 2024, out of 19,115 total FDL disbursements (1% of the population). Further, we noted the University did not have adequately designed controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues to resolve errors that were not accepted based on the original disbursement record submissions resulted in reporting corrected disbursement records to the COD later than the 15-day requirement. Possible Asserted Effect: Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding: A similar finding was reported in prior year as finding number 2024-003. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within the required timeframes. View of Responsible Official: We agree with the findings outlined in the audit report and view this as a two-part issue. First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe. To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions, Subpart E, Verification and Updating of Student Aid Application Information, (34 CFR 668) section 53(a) states an institution must establish and use written policies and procedures for verifying an applicant’s FAFSA information in accordance with the provisions. Section 53(c) states an institutions procedure must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the Higher Education Act (HEA) to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the expected family contribution (EFC). The Central Processing System (CPS) selects which applications are to be verified, but institutions have the authority to verify additional students. Institutions must report the verification results for any student whom the institution (1) received an ISIR with tracking flag V4 or V5 as selected by CPS and (2) requested verification documentation. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students selected for verification totaling $626,831 of disbursed title IV funds, we noted the following: • The US income taxes paid – parent and Education tax credits – parent reported to CPS for a V1 verification (totaling $10,667 of disbursed title IV funds) for one student was not accurate. The identity / statement of education purpose was not reported to CPS for V4/V5 verification (totaling $363,813 of disbursed title IV funds) for twenty-one students. Upon further review by the University, all of the V4/V5 students selected by CPS, a total of 130 students, (totaling $2,425,028 of disbursed title IV funds) did not have the identity / statement of education purpose submitted to the CPS during fiscal year 2024. Further, we noted the University did not have adequate controls in place to ensure that V1 and V4/V5 verification data was reported to the CPS. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues contributed to the inaccurate V1 submission and V4/V5 verifications not being submitted to the CPS. Possible Asserted Effect: Failure to accurately and completely submit student verification information to the CPS could result in Title IV funds being awarded and disbursed to student’s that are not eligible. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University strengthen processes and internal controls to ensure the University has effective internal controls in place to ensure verification are being completely and accurately submitted to the CPS. View of Responsible Official: We agree with the findings outlined in the audit report. Historically, the University has maintained strong compliance with verification requirements, and we are confident that these issues are isolated occurrences. To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students’ eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions, Subpart E, Verification and Updating of Student Aid Application Information, (34 CFR 668) section 53(a) states an institution must establish and use written policies and procedures for verifying an applicant’s FAFSA information in accordance with the provisions. Section 53(c) states an institutions procedure must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the Higher Education Act (HEA) to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the expected family contribution (EFC). The Central Processing System (CPS) selects which applications are to be verified, but institutions have the authority to verify additional students. Institutions must report the verification results for any student whom the institution (1) received an ISIR with tracking flag V4 or V5 as selected by CPS and (2) requested verification documentation. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students selected for verification totaling $626,831 of disbursed title IV funds, we noted the following: • The US income taxes paid – parent and Education tax credits – parent reported to CPS for a V1 verification (totaling $10,667 of disbursed title IV funds) for one student was not accurate. The identity / statement of education purpose was not reported to CPS for V4/V5 verification (totaling $363,813 of disbursed title IV funds) for twenty-one students. Upon further review by the University, all of the V4/V5 students selected by CPS, a total of 130 students, (totaling $2,425,028 of disbursed title IV funds) did not have the identity / statement of education purpose submitted to the CPS during fiscal year 2024. Further, we noted the University did not have adequate controls in place to ensure that V1 and V4/V5 verification data was reported to the CPS. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues contributed to the inaccurate V1 submission and V4/V5 verifications not being submitted to the CPS. Possible Asserted Effect: Failure to accurately and completely submit student verification information to the CPS could result in Title IV funds being awarded and disbursed to student’s that are not eligible. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University strengthen processes and internal controls to ensure the University has effective internal controls in place to ensure verification are being completely and accurately submitted to the CPS. View of Responsible Official: We agree with the findings outlined in the audit report. Historically, the University has maintained strong compliance with verification requirements, and we are confident that these issues are isolated occurrences. To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students’ eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions, Subpart E, Verification and Updating of Student Aid Application Information, (34 CFR 668) section 53(a) states an institution must establish and use written policies and procedures for verifying an applicant’s FAFSA information in accordance with the provisions. Section 53(c) states an institutions procedure must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the Higher Education Act (HEA) to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the expected family contribution (EFC). The Central Processing System (CPS) selects which applications are to be verified, but institutions have the authority to verify additional students. Institutions must report the verification results for any student whom the institution (1) received an ISIR with tracking flag V4 or V5 as selected by CPS and (2) requested verification documentation. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students selected for verification totaling $626,831 of disbursed title IV funds, we noted the following: • The US income taxes paid – parent and Education tax credits – parent reported to CPS for a V1 verification (totaling $10,667 of disbursed title IV funds) for one student was not accurate. The identity / statement of education purpose was not reported to CPS for V4/V5 verification (totaling $363,813 of disbursed title IV funds) for twenty-one students. Upon further review by the University, all of the V4/V5 students selected by CPS, a total of 130 students, (totaling $2,425,028 of disbursed title IV funds) did not have the identity / statement of education purpose submitted to the CPS during fiscal year 2024. Further, we noted the University did not have adequate controls in place to ensure that V1 and V4/V5 verification data was reported to the CPS. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues contributed to the inaccurate V1 submission and V4/V5 verifications not being submitted to the CPS. Possible Asserted Effect: Failure to accurately and completely submit student verification information to the CPS could result in Title IV funds being awarded and disbursed to student’s that are not eligible. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University strengthen processes and internal controls to ensure the University has effective internal controls in place to ensure verification are being completely and accurately submitted to the CPS. View of Responsible Official: We agree with the findings outlined in the audit report. Historically, the University has maintained strong compliance with verification requirements, and we are confident that these issues are isolated occurrences. To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students’ eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions, Subpart E, Verification and Updating of Student Aid Application Information, (34 CFR 668) section 53(a) states an institution must establish and use written policies and procedures for verifying an applicant’s FAFSA information in accordance with the provisions. Section 53(c) states an institutions procedure must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the Higher Education Act (HEA) to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the expected family contribution (EFC). The Central Processing System (CPS) selects which applications are to be verified, but institutions have the authority to verify additional students. Institutions must report the verification results for any student whom the institution (1) received an ISIR with tracking flag V4 or V5 as selected by CPS and (2) requested verification documentation. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students selected for verification totaling $626,831 of disbursed title IV funds, we noted the following: • The US income taxes paid – parent and Education tax credits – parent reported to CPS for a V1 verification (totaling $10,667 of disbursed title IV funds) for one student was not accurate. The identity / statement of education purpose was not reported to CPS for V4/V5 verification (totaling $363,813 of disbursed title IV funds) for twenty-one students. Upon further review by the University, all of the V4/V5 students selected by CPS, a total of 130 students, (totaling $2,425,028 of disbursed title IV funds) did not have the identity / statement of education purpose submitted to the CPS during fiscal year 2024. Further, we noted the University did not have adequate controls in place to ensure that V1 and V4/V5 verification data was reported to the CPS. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues contributed to the inaccurate V1 submission and V4/V5 verifications not being submitted to the CPS. Possible Asserted Effect: Failure to accurately and completely submit student verification information to the CPS could result in Title IV funds being awarded and disbursed to student’s that are not eligible. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University strengthen processes and internal controls to ensure the University has effective internal controls in place to ensure verification are being completely and accurately submitted to the CPS. View of Responsible Official: We agree with the findings outlined in the audit report. Historically, the University has maintained strong compliance with verification requirements, and we are confident that these issues are isolated occurrences. To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students’ eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions, Subpart E, Verification and Updating of Student Aid Application Information, (34 CFR 668) section 53(a) states an institution must establish and use written policies and procedures for verifying an applicant’s FAFSA information in accordance with the provisions. Section 53(c) states an institutions procedure must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the Higher Education Act (HEA) to make changes to the applicant’s cost of attendance or to the values of the data items required to calculate the expected family contribution (EFC). The Central Processing System (CPS) selects which applications are to be verified, but institutions have the authority to verify additional students. Institutions must report the verification results for any student whom the institution (1) received an ISIR with tracking flag V4 or V5 as selected by CPS and (2) requested verification documentation. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students selected for verification totaling $626,831 of disbursed title IV funds, we noted the following: • The US income taxes paid – parent and Education tax credits – parent reported to CPS for a V1 verification (totaling $10,667 of disbursed title IV funds) for one student was not accurate. The identity / statement of education purpose was not reported to CPS for V4/V5 verification (totaling $363,813 of disbursed title IV funds) for twenty-one students. Upon further review by the University, all of the V4/V5 students selected by CPS, a total of 130 students, (totaling $2,425,028 of disbursed title IV funds) did not have the identity / statement of education purpose submitted to the CPS during fiscal year 2024. Further, we noted the University did not have adequate controls in place to ensure that V1 and V4/V5 verification data was reported to the CPS. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues contributed to the inaccurate V1 submission and V4/V5 verifications not being submitted to the CPS. Possible Asserted Effect: Failure to accurately and completely submit student verification information to the CPS could result in Title IV funds being awarded and disbursed to student’s that are not eligible. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University strengthen processes and internal controls to ensure the University has effective internal controls in place to ensure verification are being completely and accurately submitted to the CPS. View of Responsible Official: We agree with the findings outlined in the audit report. Historically, the University has maintained strong compliance with verification requirements, and we are confident that these issues are isolated occurrences. To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students’ eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testing of 40 students with enrollment changes identified, we noted the following: The enrollment status, enrollment effective date and CIP code reported to the NSLDS for 1 student was not accurate. Specifically, the enrollment status was reported as withdrawn when the actual enrollment status of graduated, enrollment effective date was reported as December 16, 2023 when the actual enrollment effective date was December 17, 2023 and CIP code was reported as 520213 when the actual CIP code was 410101. The enrollment changes for 3 students were not reported to the NSLDS within 60 days as required. The enrollment changes were reported between 62 to 79 days after the University became aware of the change. The program beginning dates reported to the NSLDS for 16 students was not accurate. The program length reported to the NSLDS for 1 student was not accurate. Specifically, the program length was reported as 1 year when the actual program length was 3 years. Further, we noted the University’s controls were not operating effectively to ensure that enrollment changes were accurately reported to the NSLDS and reported within required timeframes. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, the inaccurate data reported was caused by human input error and not timely updating all systems after resolving NSC error reports. Further, the delayed timing in reporting was caused by certain filtering issues related to Tableau reports used to identify withdrawn students to be reported. Possible Asserted Effect: Failure to report enrollment information data to the NSLDS accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor enrollment status impacted by this data. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its internal control procedures and implement additional review procedures to ensure data is accurately reported to the NSLDS and within required timeframes. View of Responsible Official: We accept the findings noted in the audit and appreciate the recommendations provided. While we acknowledge the errors identified, we believe these were isolated instances rather than systemic issues. To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. Additionally, we are actively reviewing and revising our internal control procedures, including: Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS. Enhancing the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting. We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE’s ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions (34 CFR 668) section 165(a) states that before an institution disburses title IV, Higher Education Act of 1965, as amended (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parents can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted the University did not have appropriate monitoring controls in place to ensure the University sent required award notifications to students prior to title IV funds being accepted and disbursed. During our testing of 52 student disbursements under the FDL program totaling $151,584, we noted the University did not send an award letter notification to 2 students (with loan disbursements of $6,213) and sent an award letter notification subsequent to the first disbursement of the award year for 4 students (with loan disbursements of $23,748). Management performed a review comparing the date of all award notifications sent to Direct Loan borrowers during fiscal year 2024 to the date of Direct Loan disbursements made by the University. Management's review identified 190 (3.6% of the population) Direct Loan award notifications submitted to Direct Loan borrowers subsequent to the date of the Direct Loan disbursement out of 5,237 total Direct Loan disbursements made during fiscal year 2024. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues resulted in award notifications not being sent to students prior to disbursement. Possible Asserted Effect: Failure to notify a parent or student of the anticipated award awarded for the fiscal year results in oncompliance with FDL program requirements. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its system of internal control to ensure award notifications are made as required by FDL program regulations. View of Responsible Official: We acknowledge the finding regarding award notifications being sent to students after Title IV Direct Loan funds were disbursed in certain instances during the audit period. While the instances noted represent a small percentage of our total population (3.6%), we take compliance with federal regulations seriously and are committed to ensuring all required notifications are provided in a timely manner. The issue arose due to occasional manual intervention by staff to expedite disbursements for the benefit of students, such as addressing urgent financial needs, which moved faster than our automated system’s weekly aid offer notification process. Our current operational capacity limits the frequency of aid offer notifications to once per week, which created a gap when disbursements were accelerated manually.We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. We have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions (34 CFR 668) section 165(a) states that before an institution disburses title IV, Higher Education Act of 1965, as amended (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parents can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted the University did not have appropriate monitoring controls in place to ensure the University sent required award notifications to students prior to title IV funds being accepted and disbursed. During our testing of 52 student disbursements under the FDL program totaling $151,584, we noted the University did not send an award letter notification to 2 students (with loan disbursements of $6,213) and sent an award letter notification subsequent to the first disbursement of the award year for 4 students (with loan disbursements of $23,748). Management performed a review comparing the date of all award notifications sent to Direct Loan borrowers during fiscal year 2024 to the date of Direct Loan disbursements made by the University. Management's review identified 190 (3.6% of the population) Direct Loan award notifications submitted to Direct Loan borrowers subsequent to the date of the Direct Loan disbursement out of 5,237 total Direct Loan disbursements made during fiscal year 2024. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues resulted in award notifications not being sent to students prior to disbursement. Possible Asserted Effect: Failure to notify a parent or student of the anticipated award awarded for the fiscal year results in oncompliance with FDL program requirements. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its system of internal control to ensure award notifications are made as required by FDL program regulations. View of Responsible Official: We acknowledge the finding regarding award notifications being sent to students after Title IV Direct Loan funds were disbursed in certain instances during the audit period. While the instances noted represent a small percentage of our total population (3.6%), we take compliance with federal regulations seriously and are committed to ensuring all required notifications are provided in a timely manner. The issue arose due to occasional manual intervention by staff to expedite disbursements for the benefit of students, such as addressing urgent financial needs, which moved faster than our automated system’s weekly aid offer notification process. Our current operational capacity limits the frequency of aid offer notifications to once per week, which created a gap when disbursements were accelerated manually.We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. We have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions (34 CFR 668) section 165(a) states that before an institution disburses title IV, Higher Education Act of 1965, as amended (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parents can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted the University did not have appropriate monitoring controls in place to ensure the University sent required award notifications to students prior to title IV funds being accepted and disbursed. During our testing of 52 student disbursements under the FDL program totaling $151,584, we noted the University did not send an award letter notification to 2 students (with loan disbursements of $6,213) and sent an award letter notification subsequent to the first disbursement of the award year for 4 students (with loan disbursements of $23,748). Management performed a review comparing the date of all award notifications sent to Direct Loan borrowers during fiscal year 2024 to the date of Direct Loan disbursements made by the University. Management's review identified 190 (3.6% of the population) Direct Loan award notifications submitted to Direct Loan borrowers subsequent to the date of the Direct Loan disbursement out of 5,237 total Direct Loan disbursements made during fiscal year 2024. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues resulted in award notifications not being sent to students prior to disbursement. Possible Asserted Effect: Failure to notify a parent or student of the anticipated award awarded for the fiscal year results in oncompliance with FDL program requirements. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its system of internal control to ensure award notifications are made as required by FDL program regulations. View of Responsible Official: We acknowledge the finding regarding award notifications being sent to students after Title IV Direct Loan funds were disbursed in certain instances during the audit period. While the instances noted represent a small percentage of our total population (3.6%), we take compliance with federal regulations seriously and are committed to ensuring all required notifications are provided in a timely manner. The issue arose due to occasional manual intervention by staff to expedite disbursements for the benefit of students, such as addressing urgent financial needs, which moved faster than our automated system’s weekly aid offer notification process. Our current operational capacity limits the frequency of aid offer notifications to once per week, which created a gap when disbursements were accelerated manually.We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. We have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions (34 CFR 668) section 165(a) states that before an institution disburses title IV, Higher Education Act of 1965, as amended (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parents can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted the University did not have appropriate monitoring controls in place to ensure the University sent required award notifications to students prior to title IV funds being accepted and disbursed. During our testing of 52 student disbursements under the FDL program totaling $151,584, we noted the University did not send an award letter notification to 2 students (with loan disbursements of $6,213) and sent an award letter notification subsequent to the first disbursement of the award year for 4 students (with loan disbursements of $23,748). Management performed a review comparing the date of all award notifications sent to Direct Loan borrowers during fiscal year 2024 to the date of Direct Loan disbursements made by the University. Management's review identified 190 (3.6% of the population) Direct Loan award notifications submitted to Direct Loan borrowers subsequent to the date of the Direct Loan disbursement out of 5,237 total Direct Loan disbursements made during fiscal year 2024. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues resulted in award notifications not being sent to students prior to disbursement. Possible Asserted Effect: Failure to notify a parent or student of the anticipated award awarded for the fiscal year results in oncompliance with FDL program requirements. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its system of internal control to ensure award notifications are made as required by FDL program regulations. View of Responsible Official: We acknowledge the finding regarding award notifications being sent to students after Title IV Direct Loan funds were disbursed in certain instances during the audit period. While the instances noted represent a small percentage of our total population (3.6%), we take compliance with federal regulations seriously and are committed to ensuring all required notifications are provided in a timely manner. The issue arose due to occasional manual intervention by staff to expedite disbursements for the benefit of students, such as addressing urgent financial needs, which moved faster than our automated system’s weekly aid offer notification process. Our current operational capacity limits the frequency of aid offer notifications to once per week, which created a gap when disbursements were accelerated manually.We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. We have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353
Criteria: In accordance with Title 34 U.S. Code of Federal Regulations Part 668, Student Assistance General Provisions (34 CFR 668) section 165(a) states that before an institution disburses title IV, Higher Education Act of 1965, as amended (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parents can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Additionally, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) section 303(a) states that a nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: We noted the University did not have appropriate monitoring controls in place to ensure the University sent required award notifications to students prior to title IV funds being accepted and disbursed. During our testing of 52 student disbursements under the FDL program totaling $151,584, we noted the University did not send an award letter notification to 2 students (with loan disbursements of $6,213) and sent an award letter notification subsequent to the first disbursement of the award year for 4 students (with loan disbursements of $23,748). Management performed a review comparing the date of all award notifications sent to Direct Loan borrowers during fiscal year 2024 to the date of Direct Loan disbursements made by the University. Management's review identified 190 (3.6% of the population) Direct Loan award notifications submitted to Direct Loan borrowers subsequent to the date of the Direct Loan disbursement out of 5,237 total Direct Loan disbursements made during fiscal year 2024. Questioned Cost: There are no questioned costs. Cause: In discussing these conditions with University management, they stated that capacity issues resulted in award notifications not being sent to students prior to disbursement. Possible Asserted Effect: Failure to notify a parent or student of the anticipated award awarded for the fiscal year results in oncompliance with FDL program requirements. Repeat Finding: A similar finding was not reported in prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University review its system of internal control to ensure award notifications are made as required by FDL program regulations. View of Responsible Official: We acknowledge the finding regarding award notifications being sent to students after Title IV Direct Loan funds were disbursed in certain instances during the audit period. While the instances noted represent a small percentage of our total population (3.6%), we take compliance with federal regulations seriously and are committed to ensuring all required notifications are provided in a timely manner. The issue arose due to occasional manual intervention by staff to expedite disbursements for the benefit of students, such as addressing urgent financial needs, which moved faster than our automated system’s weekly aid offer notification process. Our current operational capacity limits the frequency of aid offer notifications to once per week, which created a gap when disbursements were accelerated manually.We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. We have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Contact Name: Alex DeLonis, Assistant Vice President for Student Financial Services Contact Telephone Number: 314-977-2353