2024-003 – Late return of Title IV funds and reviews of calculations, Cluster: Student Financial Assistance, Sponsoring Agency: Department of Education, Award Names: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Award Numbers: Various, Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, Award Year: 2023-2024, Pass-through entity: Not applicable, Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or, alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Through testing of 100 students with Title IV awards who withdrew or otherwise left the University across four campuses, we noted the following at two campuses: • 16 of 25 student selections tested at one campus required a Title IV refund to be submitted to the Department of Education. In three of the 16 instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late. • One campus has a control by which an individual reviews a report of all withdrawn students to determine if a return of Title IV calculation is required and performs the refund calculation, if applicable. This individual signs off on the withdrawn students report to indicate that all students have been reviewed and calculations completed, if necessary, and a secondary review is performed by a Compliance Officer to ensure accuracy and compliance of refunds. Through testing of 25 students and tracing them to the withdrawn students report applicable for the date of their status change, while the report and refund calculation were prepared timely, the secondary review for 14 out of the 25 selections occurred on average 115 days after the initial report was prepared. Cause: • Management at the first campus indicated that the late returns of Title IV funds were due to competing priorities and lack of training on the implications of late returns. • Management at the second campus indicated that due to staffing changes, the secondary reviews did not happen in a timely manner. Effect: The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back and lack of reviews of the calculation could result in an error being undetected. Questioned Costs: None noted. Recommendation: We recommend both campuses review their staffing and training protocols to ensure that in the event of turnover there are no gaps in the management of Title IV refund requirements and controls. Management’s Views and Corrective Action Plan: Management’s response is included in 'Management’s Views and Corrective Action Plan' included at the end of this report after the summary schedule of status of prior audit findings.
2024-003 – Late return of Title IV funds and reviews of calculations, Cluster: Student Financial Assistance, Sponsoring Agency: Department of Education, Award Names: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Award Numbers: Various, Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, Award Year: 2023-2024, Pass-through entity: Not applicable, Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or, alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Through testing of 100 students with Title IV awards who withdrew or otherwise left the University across four campuses, we noted the following at two campuses: • 16 of 25 student selections tested at one campus required a Title IV refund to be submitted to the Department of Education. In three of the 16 instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late. • One campus has a control by which an individual reviews a report of all withdrawn students to determine if a return of Title IV calculation is required and performs the refund calculation, if applicable. This individual signs off on the withdrawn students report to indicate that all students have been reviewed and calculations completed, if necessary, and a secondary review is performed by a Compliance Officer to ensure accuracy and compliance of refunds. Through testing of 25 students and tracing them to the withdrawn students report applicable for the date of their status change, while the report and refund calculation were prepared timely, the secondary review for 14 out of the 25 selections occurred on average 115 days after the initial report was prepared. Cause: • Management at the first campus indicated that the late returns of Title IV funds were due to competing priorities and lack of training on the implications of late returns. • Management at the second campus indicated that due to staffing changes, the secondary reviews did not happen in a timely manner. Effect: The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back and lack of reviews of the calculation could result in an error being undetected. Questioned Costs: None noted. Recommendation: We recommend both campuses review their staffing and training protocols to ensure that in the event of turnover there are no gaps in the management of Title IV refund requirements and controls. Management’s Views and Corrective Action Plan: Management’s response is included in 'Management’s Views and Corrective Action Plan' included at the end of this report after the summary schedule of status of prior audit findings.
2024-004 – Enrollment reporting Cluster: Not applicable Sponsoring Agency: Department of Education Award Name: Pell Grant Program and Federal Direct Student Loans Award Number: Various Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.033 and 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Criteria 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 (NSLDS). 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. (34 CFR 685.309) Additionally, 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 half-time 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). (34 CFR 685.309) Condition Through testing of 100 students across four campuses of enrollment status changes, we noted the following: • Campus 1 o Five out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 6 days late. o 11 out of 25 student selections had a graduation effective date that was not reported accurately in the program level information. o Three out of 25 student selections had status change effective dates per the student file that did not match with either program level information, campus level information, or both. • Campus 2 - Two out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 80 days late. • Campus 3 o 3 out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 73 days late. o Three out of 25 student selections had a graduation effective date that was not reported accurately in the program level or campus level information. Two of these students were also never reported as “graduated” to NSLDS, but rather remained noted as “withdrawn”. Additionally, one out of 25 student selections had a change in status that was not reflected correctly in the program level of information (the status date was 15 days prior to the actual status change date). • Campus 4 o Four out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 23 days late. o For 24 out of 25 student enrollment status change selections, the effective date of the status change date did not agree to the program level information. Additionally, for two out of 25 selections, the status change date did not agree to the campus level information. Cause • Campus 1 o The Campus takes approximately four weeks to confer degrees to graduated students, but instead of reporting the student first as withdrawn and then switching the student status to graduated upon degree conferral, the campus waited until the degree conferral process was complete to report. As such, more than 60 days had elapsed before either a withdrawn or graduation status was reported to NSLDS. o Campus personnel noted that they report the actual graduation date at the campus level, but the date reported at the program level is the last day of instruction for the term. This cadence in reporting results in the different dates being captured versus the actual graduation date being consistent in both the program level and campus level information. o Campus personnel noted that the date inconsistencies are due to data
2024-001 – Verification status code within the Common Origination and Disbursement System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grants Award Number: Various Assistance Listing Title: Federal Pell Grant Program Assistance Listing Number: 84.063 Award Year: 2023-2024 Pass-through entity: Not applicable Criteria: For each Federal Pell Grant award disbursed to a student selected for verification, a school must report the student’s verification status to the Department of Education via the Common Origination and Disbursement (COD) System. To do this, the school includes a verification status code (“W,” “V,” or “S”) in the Common Record document it submits to the COD System via batch processing or when it creates the award online via the COD website. Condition: Through testing of 100 students selected for verification by the ED across four campuses, we noted at one campus the verification status code was incorrectly reported for all students selected who received federal Pell Grant awards (21 out of 25 selections at this campus). For these selections, status code “S” was incorrectly reported instead of status code “V”. Status code “S” indicates the student was not verified because the student met certain exclusions, whereas status code “V” indicates the student has been verified. In each instance, we saw evidence the campus performed verification procedures, but did not update the status code appropriately. Cause: Through discussion with campus student financial aid personnel, the campus uses a Population Selection feature (Popsel) within Banner that allows users to select groups of people for various processes and upon looking into the cause of the condition identified above, the campus identified an error in this configuration for the 2023-2024 award year. The system was pulling an “S” based on configurations appropriate for the 2021-2022 and 2022-2023 award years when certain waivers were in place and the campus failed to revert the Popsel back to its standard configuration after the waivers were lifted for the 2023-2024 award year. Effect: As a result of this misconfiguration, the verification status code was incorrectly aligned to a given student group and the system was feeding incorrect information to the COD. As such, the Department of Education was not made aware that these students were indeed verified, as required. Questioned Costs: None noted. Recommendation: We recommend the campus establish a process to annually review guidance changes and to assess the related impact from an automated system perspective. To the extent there are changes impacting certain automated processes or other configurations, the campus should have change management procedures that are followed, including new configurations and testing of those configurations (or other changes) prior to the new award year. Management’s Views and Corrective Action Plan: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
2024-002 – Disbursement notifications and E-Sign Act Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program, Federal Direct Student Loans Award Numbers: Various Assistance Listing Titles: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.063, 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Criteria Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. Condition Through testing of 100 individual federal student financial aid award disbursements across four campuses, we noted the following at one campus: • For three out of 25 student disbursements selected for testing, the students did not receive an award letter and thus were not made aware of the amount and type of Title IV funds they were to receive and how and when those disbursements would be made. • We noted annually each student signs off on certain terms and conditions before they accept federal student assistance, however, a statement prompting the student to voluntarily consent to participate in electronic transactions was not included in the list of terms and conditions. Cause Campus personnel noted that an award letter (or other communication of award disbursements to be made) was not sent to these students due to a Population Selection feature (Popsel) within Banner that did not correctly select a certain subgroup of students. Additionally, while the campus has a Financial Responsibility Agreement that was intended to be provided annually to students when they sign-off on other Terms of Service, when looking into the matter above, campus personnel identified that this agreement has not been displayed to students since 2020. It was in the “test” system, but never moved to “production” due to management oversight. Effect If a student is not provided with notifications of disbursement prior to the disbursement, they may not be able to decline the funding, if they so choose, in a timely manner. Additionally, while there is no evidence of such events occurring with regard to the aid year under audit, a lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Questioned Costs None noted. Recommendation We recommend the campus implement controls to annually review automated processes or other configurations for completeness and accuracy. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
2024-003 – Late return of Title IV funds and reviews of calculations, Cluster: Student Financial Assistance, Sponsoring Agency: Department of Education, Award Names: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Award Numbers: Various, Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, Award Year: 2023-2024, Pass-through entity: Not applicable, Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or, alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Through testing of 100 students with Title IV awards who withdrew or otherwise left the University across four campuses, we noted the following at two campuses: • 16 of 25 student selections tested at one campus required a Title IV refund to be submitted to the Department of Education. In three of the 16 instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late. • One campus has a control by which an individual reviews a report of all withdrawn students to determine if a return of Title IV calculation is required and performs the refund calculation, if applicable. This individual signs off on the withdrawn students report to indicate that all students have been reviewed and calculations completed, if necessary, and a secondary review is performed by a Compliance Officer to ensure accuracy and compliance of refunds. Through testing of 25 students and tracing them to the withdrawn students report applicable for the date of their status change, while the report and refund calculation were prepared timely, the secondary review for 14 out of the 25 selections occurred on average 115 days after the initial report was prepared. Cause: • Management at the first campus indicated that the late returns of Title IV funds were due to competing priorities and lack of training on the implications of late returns. • Management at the second campus indicated that due to staffing changes, the secondary reviews did not happen in a timely manner. Effect: The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back and lack of reviews of the calculation could result in an error being undetected. Questioned Costs: None noted. Recommendation: We recommend both campuses review their staffing and training protocols to ensure that in the event of turnover there are no gaps in the management of Title IV refund requirements and controls. Management’s Views and Corrective Action Plan: Management’s response is included in 'Management’s Views and Corrective Action Plan' included at the end of this report after the summary schedule of status of prior audit findings.
2024-002 – Disbursement notifications and E-Sign Act Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program, Federal Direct Student Loans Award Numbers: Various Assistance Listing Titles: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.063, 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Criteria Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. Condition Through testing of 100 individual federal student financial aid award disbursements across four campuses, we noted the following at one campus: • For three out of 25 student disbursements selected for testing, the students did not receive an award letter and thus were not made aware of the amount and type of Title IV funds they were to receive and how and when those disbursements would be made. • We noted annually each student signs off on certain terms and conditions before they accept federal student assistance, however, a statement prompting the student to voluntarily consent to participate in electronic transactions was not included in the list of terms and conditions. Cause Campus personnel noted that an award letter (or other communication of award disbursements to be made) was not sent to these students due to a Population Selection feature (Popsel) within Banner that did not correctly select a certain subgroup of students. Additionally, while the campus has a Financial Responsibility Agreement that was intended to be provided annually to students when they sign-off on other Terms of Service, when looking into the matter above, campus personnel identified that this agreement has not been displayed to students since 2020. It was in the “test” system, but never moved to “production” due to management oversight. Effect If a student is not provided with notifications of disbursement prior to the disbursement, they may not be able to decline the funding, if they so choose, in a timely manner. Additionally, while there is no evidence of such events occurring with regard to the aid year under audit, a lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Questioned Costs None noted. Recommendation We recommend the campus implement controls to annually review automated processes or other configurations for completeness and accuracy. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
2024-003 – Late return of Title IV funds and reviews of calculations, Cluster: Student Financial Assistance, Sponsoring Agency: Department of Education, Award Names: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Award Numbers: Various, Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, Award Year: 2023-2024, Pass-through entity: Not applicable, Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or, alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Through testing of 100 students with Title IV awards who withdrew or otherwise left the University across four campuses, we noted the following at two campuses: • 16 of 25 student selections tested at one campus required a Title IV refund to be submitted to the Department of Education. In three of the 16 instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late. • One campus has a control by which an individual reviews a report of all withdrawn students to determine if a return of Title IV calculation is required and performs the refund calculation, if applicable. This individual signs off on the withdrawn students report to indicate that all students have been reviewed and calculations completed, if necessary, and a secondary review is performed by a Compliance Officer to ensure accuracy and compliance of refunds. Through testing of 25 students and tracing them to the withdrawn students report applicable for the date of their status change, while the report and refund calculation were prepared timely, the secondary review for 14 out of the 25 selections occurred on average 115 days after the initial report was prepared. Cause: • Management at the first campus indicated that the late returns of Title IV funds were due to competing priorities and lack of training on the implications of late returns. • Management at the second campus indicated that due to staffing changes, the secondary reviews did not happen in a timely manner. Effect: The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back and lack of reviews of the calculation could result in an error being undetected. Questioned Costs: None noted. Recommendation: We recommend both campuses review their staffing and training protocols to ensure that in the event of turnover there are no gaps in the management of Title IV refund requirements and controls. Management’s Views and Corrective Action Plan: Management’s response is included in 'Management’s Views and Corrective Action Plan' included at the end of this report after the summary schedule of status of prior audit findings.
2024-004 – Enrollment reporting Cluster: Not applicable Sponsoring Agency: Department of Education Award Name: Pell Grant Program and Federal Direct Student Loans Award Number: Various Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.033 and 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Criteria 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 (NSLDS). 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. (34 CFR 685.309) Additionally, 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 half-time 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). (34 CFR 685.309) Condition Through testing of 100 students across four campuses of enrollment status changes, we noted the following: • Campus 1 o Five out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 6 days late. o 11 out of 25 student selections had a graduation effective date that was not reported accurately in the program level information. o Three out of 25 student selections had status change effective dates per the student file that did not match with either program level information, campus level information, or both. • Campus 2 - Two out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 80 days late. • Campus 3 o 3 out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 73 days late. o Three out of 25 student selections had a graduation effective date that was not reported accurately in the program level or campus level information. Two of these students were also never reported as “graduated” to NSLDS, but rather remained noted as “withdrawn”. Additionally, one out of 25 student selections had a change in status that was not reflected correctly in the program level of information (the status date was 15 days prior to the actual status change date). • Campus 4 o Four out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 23 days late. o For 24 out of 25 student enrollment status change selections, the effective date of the status change date did not agree to the program level information. Additionally, for two out of 25 selections, the status change date did not agree to the campus level information. Cause • Campus 1 o The Campus takes approximately four weeks to confer degrees to graduated students, but instead of reporting the student first as withdrawn and then switching the student status to graduated upon degree conferral, the campus waited until the degree conferral process was complete to report. As such, more than 60 days had elapsed before either a withdrawn or graduation status was reported to NSLDS. o Campus personnel noted that they report the actual graduation date at the campus level, but the date reported at the program level is the last day of instruction for the term. This cadence in reporting results in the different dates being captured versus the actual graduation date being consistent in both the program level and campus level information. o Campus personnel noted that the date inconsistencies are due to data
2024-003 – Late return of Title IV funds and reviews of calculations, Cluster: Student Financial Assistance, Sponsoring Agency: Department of Education, Award Names: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Award Numbers: Various, Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, Award Year: 2023-2024, Pass-through entity: Not applicable, Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or, alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Through testing of 100 students with Title IV awards who withdrew or otherwise left the University across four campuses, we noted the following at two campuses: • 16 of 25 student selections tested at one campus required a Title IV refund to be submitted to the Department of Education. In three of the 16 instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late. • One campus has a control by which an individual reviews a report of all withdrawn students to determine if a return of Title IV calculation is required and performs the refund calculation, if applicable. This individual signs off on the withdrawn students report to indicate that all students have been reviewed and calculations completed, if necessary, and a secondary review is performed by a Compliance Officer to ensure accuracy and compliance of refunds. Through testing of 25 students and tracing them to the withdrawn students report applicable for the date of their status change, while the report and refund calculation were prepared timely, the secondary review for 14 out of the 25 selections occurred on average 115 days after the initial report was prepared. Cause: • Management at the first campus indicated that the late returns of Title IV funds were due to competing priorities and lack of training on the implications of late returns. • Management at the second campus indicated that due to staffing changes, the secondary reviews did not happen in a timely manner. Effect: The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back and lack of reviews of the calculation could result in an error being undetected. Questioned Costs: None noted. Recommendation: We recommend both campuses review their staffing and training protocols to ensure that in the event of turnover there are no gaps in the management of Title IV refund requirements and controls. Management’s Views and Corrective Action Plan: Management’s response is included in 'Management’s Views and Corrective Action Plan' included at the end of this report after the summary schedule of status of prior audit findings.
2024-003 – Late return of Title IV funds and reviews of calculations, Cluster: Student Financial Assistance, Sponsoring Agency: Department of Education, Award Names: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Award Numbers: Various, Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, Award Year: 2023-2024, Pass-through entity: Not applicable, Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or, alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Through testing of 100 students with Title IV awards who withdrew or otherwise left the University across four campuses, we noted the following at two campuses: • 16 of 25 student selections tested at one campus required a Title IV refund to be submitted to the Department of Education. In three of the 16 instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late. • One campus has a control by which an individual reviews a report of all withdrawn students to determine if a return of Title IV calculation is required and performs the refund calculation, if applicable. This individual signs off on the withdrawn students report to indicate that all students have been reviewed and calculations completed, if necessary, and a secondary review is performed by a Compliance Officer to ensure accuracy and compliance of refunds. Through testing of 25 students and tracing them to the withdrawn students report applicable for the date of their status change, while the report and refund calculation were prepared timely, the secondary review for 14 out of the 25 selections occurred on average 115 days after the initial report was prepared. Cause: • Management at the first campus indicated that the late returns of Title IV funds were due to competing priorities and lack of training on the implications of late returns. • Management at the second campus indicated that due to staffing changes, the secondary reviews did not happen in a timely manner. Effect: The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back and lack of reviews of the calculation could result in an error being undetected. Questioned Costs: None noted. Recommendation: We recommend both campuses review their staffing and training protocols to ensure that in the event of turnover there are no gaps in the management of Title IV refund requirements and controls. Management’s Views and Corrective Action Plan: Management’s response is included in 'Management’s Views and Corrective Action Plan' included at the end of this report after the summary schedule of status of prior audit findings.
2024-004 – Enrollment reporting Cluster: Not applicable Sponsoring Agency: Department of Education Award Name: Pell Grant Program and Federal Direct Student Loans Award Number: Various Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.033 and 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Criteria 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 (NSLDS). 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. (34 CFR 685.309) Additionally, 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 half-time 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). (34 CFR 685.309) Condition Through testing of 100 students across four campuses of enrollment status changes, we noted the following: • Campus 1 o Five out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 6 days late. o 11 out of 25 student selections had a graduation effective date that was not reported accurately in the program level information. o Three out of 25 student selections had status change effective dates per the student file that did not match with either program level information, campus level information, or both. • Campus 2 - Two out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 80 days late. • Campus 3 o 3 out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 73 days late. o Three out of 25 student selections had a graduation effective date that was not reported accurately in the program level or campus level information. Two of these students were also never reported as “graduated” to NSLDS, but rather remained noted as “withdrawn”. Additionally, one out of 25 student selections had a change in status that was not reflected correctly in the program level of information (the status date was 15 days prior to the actual status change date). • Campus 4 o Four out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 23 days late. o For 24 out of 25 student enrollment status change selections, the effective date of the status change date did not agree to the program level information. Additionally, for two out of 25 selections, the status change date did not agree to the campus level information. Cause • Campus 1 o The Campus takes approximately four weeks to confer degrees to graduated students, but instead of reporting the student first as withdrawn and then switching the student status to graduated upon degree conferral, the campus waited until the degree conferral process was complete to report. As such, more than 60 days had elapsed before either a withdrawn or graduation status was reported to NSLDS. o Campus personnel noted that they report the actual graduation date at the campus level, but the date reported at the program level is the last day of instruction for the term. This cadence in reporting results in the different dates being captured versus the actual graduation date being consistent in both the program level and campus level information. o Campus personnel noted that the date inconsistencies are due to data
2024-001 – Verification status code within the Common Origination and Disbursement System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grants Award Number: Various Assistance Listing Title: Federal Pell Grant Program Assistance Listing Number: 84.063 Award Year: 2023-2024 Pass-through entity: Not applicable Criteria: For each Federal Pell Grant award disbursed to a student selected for verification, a school must report the student’s verification status to the Department of Education via the Common Origination and Disbursement (COD) System. To do this, the school includes a verification status code (“W,” “V,” or “S”) in the Common Record document it submits to the COD System via batch processing or when it creates the award online via the COD website. Condition: Through testing of 100 students selected for verification by the ED across four campuses, we noted at one campus the verification status code was incorrectly reported for all students selected who received federal Pell Grant awards (21 out of 25 selections at this campus). For these selections, status code “S” was incorrectly reported instead of status code “V”. Status code “S” indicates the student was not verified because the student met certain exclusions, whereas status code “V” indicates the student has been verified. In each instance, we saw evidence the campus performed verification procedures, but did not update the status code appropriately. Cause: Through discussion with campus student financial aid personnel, the campus uses a Population Selection feature (Popsel) within Banner that allows users to select groups of people for various processes and upon looking into the cause of the condition identified above, the campus identified an error in this configuration for the 2023-2024 award year. The system was pulling an “S” based on configurations appropriate for the 2021-2022 and 2022-2023 award years when certain waivers were in place and the campus failed to revert the Popsel back to its standard configuration after the waivers were lifted for the 2023-2024 award year. Effect: As a result of this misconfiguration, the verification status code was incorrectly aligned to a given student group and the system was feeding incorrect information to the COD. As such, the Department of Education was not made aware that these students were indeed verified, as required. Questioned Costs: None noted. Recommendation: We recommend the campus establish a process to annually review guidance changes and to assess the related impact from an automated system perspective. To the extent there are changes impacting certain automated processes or other configurations, the campus should have change management procedures that are followed, including new configurations and testing of those configurations (or other changes) prior to the new award year. Management’s Views and Corrective Action Plan: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
2024-002 – Disbursement notifications and E-Sign Act Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program, Federal Direct Student Loans Award Numbers: Various Assistance Listing Titles: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.063, 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Criteria Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. Condition Through testing of 100 individual federal student financial aid award disbursements across four campuses, we noted the following at one campus: • For three out of 25 student disbursements selected for testing, the students did not receive an award letter and thus were not made aware of the amount and type of Title IV funds they were to receive and how and when those disbursements would be made. • We noted annually each student signs off on certain terms and conditions before they accept federal student assistance, however, a statement prompting the student to voluntarily consent to participate in electronic transactions was not included in the list of terms and conditions. Cause Campus personnel noted that an award letter (or other communication of award disbursements to be made) was not sent to these students due to a Population Selection feature (Popsel) within Banner that did not correctly select a certain subgroup of students. Additionally, while the campus has a Financial Responsibility Agreement that was intended to be provided annually to students when they sign-off on other Terms of Service, when looking into the matter above, campus personnel identified that this agreement has not been displayed to students since 2020. It was in the “test” system, but never moved to “production” due to management oversight. Effect If a student is not provided with notifications of disbursement prior to the disbursement, they may not be able to decline the funding, if they so choose, in a timely manner. Additionally, while there is no evidence of such events occurring with regard to the aid year under audit, a lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Questioned Costs None noted. Recommendation We recommend the campus implement controls to annually review automated processes or other configurations for completeness and accuracy. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
2024-003 – Late return of Title IV funds and reviews of calculations, Cluster: Student Financial Assistance, Sponsoring Agency: Department of Education, Award Names: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Award Numbers: Various, Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, Award Year: 2023-2024, Pass-through entity: Not applicable, Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or, alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Through testing of 100 students with Title IV awards who withdrew or otherwise left the University across four campuses, we noted the following at two campuses: • 16 of 25 student selections tested at one campus required a Title IV refund to be submitted to the Department of Education. In three of the 16 instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late. • One campus has a control by which an individual reviews a report of all withdrawn students to determine if a return of Title IV calculation is required and performs the refund calculation, if applicable. This individual signs off on the withdrawn students report to indicate that all students have been reviewed and calculations completed, if necessary, and a secondary review is performed by a Compliance Officer to ensure accuracy and compliance of refunds. Through testing of 25 students and tracing them to the withdrawn students report applicable for the date of their status change, while the report and refund calculation were prepared timely, the secondary review for 14 out of the 25 selections occurred on average 115 days after the initial report was prepared. Cause: • Management at the first campus indicated that the late returns of Title IV funds were due to competing priorities and lack of training on the implications of late returns. • Management at the second campus indicated that due to staffing changes, the secondary reviews did not happen in a timely manner. Effect: The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back and lack of reviews of the calculation could result in an error being undetected. Questioned Costs: None noted. Recommendation: We recommend both campuses review their staffing and training protocols to ensure that in the event of turnover there are no gaps in the management of Title IV refund requirements and controls. Management’s Views and Corrective Action Plan: Management’s response is included in 'Management’s Views and Corrective Action Plan' included at the end of this report after the summary schedule of status of prior audit findings.
2024-002 – Disbursement notifications and E-Sign Act Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program, Federal Direct Student Loans Award Numbers: Various Assistance Listing Titles: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.063, 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Criteria Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. Condition Through testing of 100 individual federal student financial aid award disbursements across four campuses, we noted the following at one campus: • For three out of 25 student disbursements selected for testing, the students did not receive an award letter and thus were not made aware of the amount and type of Title IV funds they were to receive and how and when those disbursements would be made. • We noted annually each student signs off on certain terms and conditions before they accept federal student assistance, however, a statement prompting the student to voluntarily consent to participate in electronic transactions was not included in the list of terms and conditions. Cause Campus personnel noted that an award letter (or other communication of award disbursements to be made) was not sent to these students due to a Population Selection feature (Popsel) within Banner that did not correctly select a certain subgroup of students. Additionally, while the campus has a Financial Responsibility Agreement that was intended to be provided annually to students when they sign-off on other Terms of Service, when looking into the matter above, campus personnel identified that this agreement has not been displayed to students since 2020. It was in the “test” system, but never moved to “production” due to management oversight. Effect If a student is not provided with notifications of disbursement prior to the disbursement, they may not be able to decline the funding, if they so choose, in a timely manner. Additionally, while there is no evidence of such events occurring with regard to the aid year under audit, a lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Questioned Costs None noted. Recommendation We recommend the campus implement controls to annually review automated processes or other configurations for completeness and accuracy. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
2024-003 – Late return of Title IV funds and reviews of calculations, Cluster: Student Financial Assistance, Sponsoring Agency: Department of Education, Award Names: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Award Numbers: Various, Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans, Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, Award Year: 2023-2024, Pass-through entity: Not applicable, Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or, alternatively, electronic fund transfers are required to be initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Additionally, 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Through testing of 100 students with Title IV awards who withdrew or otherwise left the University across four campuses, we noted the following at two campuses: • 16 of 25 student selections tested at one campus required a Title IV refund to be submitted to the Department of Education. In three of the 16 instances, the refund was not submitted to the Department of Education within 45 days. On average, they were submitted 61 days late. • One campus has a control by which an individual reviews a report of all withdrawn students to determine if a return of Title IV calculation is required and performs the refund calculation, if applicable. This individual signs off on the withdrawn students report to indicate that all students have been reviewed and calculations completed, if necessary, and a secondary review is performed by a Compliance Officer to ensure accuracy and compliance of refunds. Through testing of 25 students and tracing them to the withdrawn students report applicable for the date of their status change, while the report and refund calculation were prepared timely, the secondary review for 14 out of the 25 selections occurred on average 115 days after the initial report was prepared. Cause: • Management at the first campus indicated that the late returns of Title IV funds were due to competing priorities and lack of training on the implications of late returns. • Management at the second campus indicated that due to staffing changes, the secondary reviews did not happen in a timely manner. Effect: The lack of timeliness in the return of Title IV aid could result in the University accruing additional interest that will need to be assessed and paid back and lack of reviews of the calculation could result in an error being undetected. Questioned Costs: None noted. Recommendation: We recommend both campuses review their staffing and training protocols to ensure that in the event of turnover there are no gaps in the management of Title IV refund requirements and controls. Management’s Views and Corrective Action Plan: Management’s response is included in 'Management’s Views and Corrective Action Plan' included at the end of this report after the summary schedule of status of prior audit findings.
2024-004 – Enrollment reporting Cluster: Not applicable Sponsoring Agency: Department of Education Award Name: Pell Grant Program and Federal Direct Student Loans Award Number: Various Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.033 and 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Criteria 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 (NSLDS). 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. (34 CFR 685.309) Additionally, 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 half-time 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). (34 CFR 685.309) Condition Through testing of 100 students across four campuses of enrollment status changes, we noted the following: • Campus 1 o Five out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 6 days late. o 11 out of 25 student selections had a graduation effective date that was not reported accurately in the program level information. o Three out of 25 student selections had status change effective dates per the student file that did not match with either program level information, campus level information, or both. • Campus 2 - Two out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 80 days late. • Campus 3 o 3 out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 73 days late. o Three out of 25 student selections had a graduation effective date that was not reported accurately in the program level or campus level information. Two of these students were also never reported as “graduated” to NSLDS, but rather remained noted as “withdrawn”. Additionally, one out of 25 student selections had a change in status that was not reflected correctly in the program level of information (the status date was 15 days prior to the actual status change date). • Campus 4 o Four out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 23 days late. o For 24 out of 25 student enrollment status change selections, the effective date of the status change date did not agree to the program level information. Additionally, for two out of 25 selections, the status change date did not agree to the campus level information. Cause • Campus 1 o The Campus takes approximately four weeks to confer degrees to graduated students, but instead of reporting the student first as withdrawn and then switching the student status to graduated upon degree conferral, the campus waited until the degree conferral process was complete to report. As such, more than 60 days had elapsed before either a withdrawn or graduation status was reported to NSLDS. o Campus personnel noted that they report the actual graduation date at the campus level, but the date reported at the program level is the last day of instruction for the term. This cadence in reporting results in the different dates being captured versus the actual graduation date being consistent in both the program level and campus level information. o Campus personnel noted that the date inconsistencies are due to data