Finding 2024-002 - Significant Deficiency, Compliance
Federal Assistance Listing Number. 84.063, 84.268
U.S. Department Of Education
Student Financial Aid Cluster – Special Tests And Provisions – R2T4
Criteria: According to Chapter 2 of Volume 5 of the 2023-2024 Federal Student Aid (FSA) Handbook scheduled breaks of more than 5 days are required to be excluded from the length of the term for purposes of the Return to Title IV (R2T4) calculation. Further, where classes end on a Friday and do not resume until Monday following a one-week break, both weekends (four days) and the five weekdays would be excluded from the R2T4 calculation, for a total of nine days.
Condition: In our nonstatistical sample of 5 R2T4 calculations completed in the year ended June 30, 2024, we identified one instance where the University improperly calculated the number of days in the Spring 2024 semester used in the denominator of the percentage of aid earned calculation.
Context: We noted for the one student that the University used 10 days of scheduled breaks (5 for Spring Break and 5 for Easter Break) which excluded the weekend dates surrounding the week of Spring Break. The University should have included the weekend dates prior to the week of Spring Break and after the week of Spring Break resulting in 14 days of scheduled breaks used in the denominator of the calculation.
Effect: As a result of the miscalculation the school was required to return $104 more of the student’s Pell grant than should have been required. There was only one other Spring 2024 R2T4 calculation completed which would have resulted in the additional student earning $2 more in Pell grant than the University calculated.
Questioned Costs: There were no questioned costs as the University returned more funding than required.
Cause: The University did not have a properly designed internal control structure to ensure the academic calendar was established to properly account for the scheduled breaks for purposes of determining the denominator in the earned aid calculation.
Identification Of Repeat Finding: This is not a repeat finding.
Recommendation: The University should correct the two Spring 2024 RT24 calculations and disburse to the students the additional Pell grant funds that the students earned. The University should correct its calculation for Spring Break for the 2024-2025 academic year.
Views Of Responsible Officials (Unaudited): The University concurs with the finding. The University has corrected the two Spring 2024 RT24 calculations and initiated additional Pell grant disbursements to the noted students. The University has updated its calculations of the scheduled breaks for the 2024-2025 academic year.
Completion Date: August 2024
Contact Person: Megan Morton, Director of Financial Services
Finding 2024-003 - Significant Deficiency, Compliance
Federal Assistance Listing Number. 84.063, 84.268
U.S. Department Of Education
Student Financial Aid Cluster – Reporting
Criteria: According to the 2023-2024 COD Technical Reference and 2023-2024 FSA Handbook, the University must report accurate disbursement dates to Common Origination Disbursement (COD) for all direct loan and pell grant disbursements made to students.
Condition: In our nonstatistical sample of 40 students, we noted 13 students whose disbursement dates listed in the University’s student ledger differed from the date reported as the disbursement date within COD as reported by the University.
Context: For the 13 students noted there were a total of 17 disbursements of Pell grant, subsidized loan, unsubsidized loan, and PLUS loan disbursements. Of the 17 disbursement date exceptions noted, 11 of the disbursement dates reported in COD differed by 6 days or less, while 6 of the disbursement dates reported in COD differed by 20 days or more from the date of disbursement noted in the University’s student ledger.
Effect: Improperly reported disbursement dates could impact the amount of interest charged to the student or impact the ability for the University or the U.S. Department of Education to properly reconcile disbursement and drawdown data.
Questioned Costs: There were no questioned costs related to this finding.
Cause: The University’s original disbursement date that was reported to COD was not updated with the updated disbursement date when the updated batch reporting occurred for these students after the student’s original planned disbursement date had passed.
Identification Of Repeat Finding: This is not a repeat finding.
Recommendation: The University should correct the disbursement dates for the students that it knows have disbursement dates reported to COD that differ from the dates in the University’s student ledger for the year ended June 30, 2024. The University should implement controls to ensure that a review is completed of the batch uploads to COD to ensure that the disbursement dates are accurately reported.
Views Of Responsible Officials (Unaudited): The University concurs with the finding and has made t the required corrections to the COD disbursement dates. The University process when posting Aid has remained consistent each year, this appears to be an isolated incident where CAMS did not pick up the date listed on the disbursement screen for these students and pass that to COD. The University has implemented a control to complete the disbursements each time and then verify the date reflects correctly in COD afterwards. While this should be an automatic process, and has been in previous years, it will be something the University verifies now with each aid posting.
Completion Date: August 2024
Contact Person: Megan Morton, Director of Financial Services
Finding 2024-002 - Significant Deficiency, Compliance
Federal Assistance Listing Number. 84.063, 84.268
U.S. Department Of Education
Student Financial Aid Cluster – Special Tests And Provisions – R2T4
Criteria: According to Chapter 2 of Volume 5 of the 2023-2024 Federal Student Aid (FSA) Handbook scheduled breaks of more than 5 days are required to be excluded from the length of the term for purposes of the Return to Title IV (R2T4) calculation. Further, where classes end on a Friday and do not resume until Monday following a one-week break, both weekends (four days) and the five weekdays would be excluded from the R2T4 calculation, for a total of nine days.
Condition: In our nonstatistical sample of 5 R2T4 calculations completed in the year ended June 30, 2024, we identified one instance where the University improperly calculated the number of days in the Spring 2024 semester used in the denominator of the percentage of aid earned calculation.
Context: We noted for the one student that the University used 10 days of scheduled breaks (5 for Spring Break and 5 for Easter Break) which excluded the weekend dates surrounding the week of Spring Break. The University should have included the weekend dates prior to the week of Spring Break and after the week of Spring Break resulting in 14 days of scheduled breaks used in the denominator of the calculation.
Effect: As a result of the miscalculation the school was required to return $104 more of the student’s Pell grant than should have been required. There was only one other Spring 2024 R2T4 calculation completed which would have resulted in the additional student earning $2 more in Pell grant than the University calculated.
Questioned Costs: There were no questioned costs as the University returned more funding than required.
Cause: The University did not have a properly designed internal control structure to ensure the academic calendar was established to properly account for the scheduled breaks for purposes of determining the denominator in the earned aid calculation.
Identification Of Repeat Finding: This is not a repeat finding.
Recommendation: The University should correct the two Spring 2024 RT24 calculations and disburse to the students the additional Pell grant funds that the students earned. The University should correct its calculation for Spring Break for the 2024-2025 academic year.
Views Of Responsible Officials (Unaudited): The University concurs with the finding. The University has corrected the two Spring 2024 RT24 calculations and initiated additional Pell grant disbursements to the noted students. The University has updated its calculations of the scheduled breaks for the 2024-2025 academic year.
Completion Date: August 2024
Contact Person: Megan Morton, Director of Financial Services
Finding 2024-003 - Significant Deficiency, Compliance
Federal Assistance Listing Number. 84.063, 84.268
U.S. Department Of Education
Student Financial Aid Cluster – Reporting
Criteria: According to the 2023-2024 COD Technical Reference and 2023-2024 FSA Handbook, the University must report accurate disbursement dates to Common Origination Disbursement (COD) for all direct loan and pell grant disbursements made to students.
Condition: In our nonstatistical sample of 40 students, we noted 13 students whose disbursement dates listed in the University’s student ledger differed from the date reported as the disbursement date within COD as reported by the University.
Context: For the 13 students noted there were a total of 17 disbursements of Pell grant, subsidized loan, unsubsidized loan, and PLUS loan disbursements. Of the 17 disbursement date exceptions noted, 11 of the disbursement dates reported in COD differed by 6 days or less, while 6 of the disbursement dates reported in COD differed by 20 days or more from the date of disbursement noted in the University’s student ledger.
Effect: Improperly reported disbursement dates could impact the amount of interest charged to the student or impact the ability for the University or the U.S. Department of Education to properly reconcile disbursement and drawdown data.
Questioned Costs: There were no questioned costs related to this finding.
Cause: The University’s original disbursement date that was reported to COD was not updated with the updated disbursement date when the updated batch reporting occurred for these students after the student’s original planned disbursement date had passed.
Identification Of Repeat Finding: This is not a repeat finding.
Recommendation: The University should correct the disbursement dates for the students that it knows have disbursement dates reported to COD that differ from the dates in the University’s student ledger for the year ended June 30, 2024. The University should implement controls to ensure that a review is completed of the batch uploads to COD to ensure that the disbursement dates are accurately reported.
Views Of Responsible Officials (Unaudited): The University concurs with the finding and has made t the required corrections to the COD disbursement dates. The University process when posting Aid has remained consistent each year, this appears to be an isolated incident where CAMS did not pick up the date listed on the disbursement screen for these students and pass that to COD. The University has implemented a control to complete the disbursements each time and then verify the date reflects correctly in COD afterwards. While this should be an automatic process, and has been in previous years, it will be something the University verifies now with each aid posting.
Completion Date: August 2024
Contact Person: Megan Morton, Director of Financial Services
Finding 2024-002 - Significant Deficiency, Compliance
Federal Assistance Listing Number. 84.063, 84.268
U.S. Department Of Education
Student Financial Aid Cluster – Special Tests And Provisions – R2T4
Criteria: According to Chapter 2 of Volume 5 of the 2023-2024 Federal Student Aid (FSA) Handbook scheduled breaks of more than 5 days are required to be excluded from the length of the term for purposes of the Return to Title IV (R2T4) calculation. Further, where classes end on a Friday and do not resume until Monday following a one-week break, both weekends (four days) and the five weekdays would be excluded from the R2T4 calculation, for a total of nine days.
Condition: In our nonstatistical sample of 5 R2T4 calculations completed in the year ended June 30, 2024, we identified one instance where the University improperly calculated the number of days in the Spring 2024 semester used in the denominator of the percentage of aid earned calculation.
Context: We noted for the one student that the University used 10 days of scheduled breaks (5 for Spring Break and 5 for Easter Break) which excluded the weekend dates surrounding the week of Spring Break. The University should have included the weekend dates prior to the week of Spring Break and after the week of Spring Break resulting in 14 days of scheduled breaks used in the denominator of the calculation.
Effect: As a result of the miscalculation the school was required to return $104 more of the student’s Pell grant than should have been required. There was only one other Spring 2024 R2T4 calculation completed which would have resulted in the additional student earning $2 more in Pell grant than the University calculated.
Questioned Costs: There were no questioned costs as the University returned more funding than required.
Cause: The University did not have a properly designed internal control structure to ensure the academic calendar was established to properly account for the scheduled breaks for purposes of determining the denominator in the earned aid calculation.
Identification Of Repeat Finding: This is not a repeat finding.
Recommendation: The University should correct the two Spring 2024 RT24 calculations and disburse to the students the additional Pell grant funds that the students earned. The University should correct its calculation for Spring Break for the 2024-2025 academic year.
Views Of Responsible Officials (Unaudited): The University concurs with the finding. The University has corrected the two Spring 2024 RT24 calculations and initiated additional Pell grant disbursements to the noted students. The University has updated its calculations of the scheduled breaks for the 2024-2025 academic year.
Completion Date: August 2024
Contact Person: Megan Morton, Director of Financial Services
Finding 2024-003 - Significant Deficiency, Compliance
Federal Assistance Listing Number. 84.063, 84.268
U.S. Department Of Education
Student Financial Aid Cluster – Reporting
Criteria: According to the 2023-2024 COD Technical Reference and 2023-2024 FSA Handbook, the University must report accurate disbursement dates to Common Origination Disbursement (COD) for all direct loan and pell grant disbursements made to students.
Condition: In our nonstatistical sample of 40 students, we noted 13 students whose disbursement dates listed in the University’s student ledger differed from the date reported as the disbursement date within COD as reported by the University.
Context: For the 13 students noted there were a total of 17 disbursements of Pell grant, subsidized loan, unsubsidized loan, and PLUS loan disbursements. Of the 17 disbursement date exceptions noted, 11 of the disbursement dates reported in COD differed by 6 days or less, while 6 of the disbursement dates reported in COD differed by 20 days or more from the date of disbursement noted in the University’s student ledger.
Effect: Improperly reported disbursement dates could impact the amount of interest charged to the student or impact the ability for the University or the U.S. Department of Education to properly reconcile disbursement and drawdown data.
Questioned Costs: There were no questioned costs related to this finding.
Cause: The University’s original disbursement date that was reported to COD was not updated with the updated disbursement date when the updated batch reporting occurred for these students after the student’s original planned disbursement date had passed.
Identification Of Repeat Finding: This is not a repeat finding.
Recommendation: The University should correct the disbursement dates for the students that it knows have disbursement dates reported to COD that differ from the dates in the University’s student ledger for the year ended June 30, 2024. The University should implement controls to ensure that a review is completed of the batch uploads to COD to ensure that the disbursement dates are accurately reported.
Views Of Responsible Officials (Unaudited): The University concurs with the finding and has made t the required corrections to the COD disbursement dates. The University process when posting Aid has remained consistent each year, this appears to be an isolated incident where CAMS did not pick up the date listed on the disbursement screen for these students and pass that to COD. The University has implemented a control to complete the disbursements each time and then verify the date reflects correctly in COD afterwards. While this should be an automatic process, and has been in previous years, it will be something the University verifies now with each aid posting.
Completion Date: August 2024
Contact Person: Megan Morton, Director of Financial Services
Finding 2024-002 - Significant Deficiency, Compliance
Federal Assistance Listing Number. 84.063, 84.268
U.S. Department Of Education
Student Financial Aid Cluster – Special Tests And Provisions – R2T4
Criteria: According to Chapter 2 of Volume 5 of the 2023-2024 Federal Student Aid (FSA) Handbook scheduled breaks of more than 5 days are required to be excluded from the length of the term for purposes of the Return to Title IV (R2T4) calculation. Further, where classes end on a Friday and do not resume until Monday following a one-week break, both weekends (four days) and the five weekdays would be excluded from the R2T4 calculation, for a total of nine days.
Condition: In our nonstatistical sample of 5 R2T4 calculations completed in the year ended June 30, 2024, we identified one instance where the University improperly calculated the number of days in the Spring 2024 semester used in the denominator of the percentage of aid earned calculation.
Context: We noted for the one student that the University used 10 days of scheduled breaks (5 for Spring Break and 5 for Easter Break) which excluded the weekend dates surrounding the week of Spring Break. The University should have included the weekend dates prior to the week of Spring Break and after the week of Spring Break resulting in 14 days of scheduled breaks used in the denominator of the calculation.
Effect: As a result of the miscalculation the school was required to return $104 more of the student’s Pell grant than should have been required. There was only one other Spring 2024 R2T4 calculation completed which would have resulted in the additional student earning $2 more in Pell grant than the University calculated.
Questioned Costs: There were no questioned costs as the University returned more funding than required.
Cause: The University did not have a properly designed internal control structure to ensure the academic calendar was established to properly account for the scheduled breaks for purposes of determining the denominator in the earned aid calculation.
Identification Of Repeat Finding: This is not a repeat finding.
Recommendation: The University should correct the two Spring 2024 RT24 calculations and disburse to the students the additional Pell grant funds that the students earned. The University should correct its calculation for Spring Break for the 2024-2025 academic year.
Views Of Responsible Officials (Unaudited): The University concurs with the finding. The University has corrected the two Spring 2024 RT24 calculations and initiated additional Pell grant disbursements to the noted students. The University has updated its calculations of the scheduled breaks for the 2024-2025 academic year.
Completion Date: August 2024
Contact Person: Megan Morton, Director of Financial Services
Finding 2024-003 - Significant Deficiency, Compliance
Federal Assistance Listing Number. 84.063, 84.268
U.S. Department Of Education
Student Financial Aid Cluster – Reporting
Criteria: According to the 2023-2024 COD Technical Reference and 2023-2024 FSA Handbook, the University must report accurate disbursement dates to Common Origination Disbursement (COD) for all direct loan and pell grant disbursements made to students.
Condition: In our nonstatistical sample of 40 students, we noted 13 students whose disbursement dates listed in the University’s student ledger differed from the date reported as the disbursement date within COD as reported by the University.
Context: For the 13 students noted there were a total of 17 disbursements of Pell grant, subsidized loan, unsubsidized loan, and PLUS loan disbursements. Of the 17 disbursement date exceptions noted, 11 of the disbursement dates reported in COD differed by 6 days or less, while 6 of the disbursement dates reported in COD differed by 20 days or more from the date of disbursement noted in the University’s student ledger.
Effect: Improperly reported disbursement dates could impact the amount of interest charged to the student or impact the ability for the University or the U.S. Department of Education to properly reconcile disbursement and drawdown data.
Questioned Costs: There were no questioned costs related to this finding.
Cause: The University’s original disbursement date that was reported to COD was not updated with the updated disbursement date when the updated batch reporting occurred for these students after the student’s original planned disbursement date had passed.
Identification Of Repeat Finding: This is not a repeat finding.
Recommendation: The University should correct the disbursement dates for the students that it knows have disbursement dates reported to COD that differ from the dates in the University’s student ledger for the year ended June 30, 2024. The University should implement controls to ensure that a review is completed of the batch uploads to COD to ensure that the disbursement dates are accurately reported.
Views Of Responsible Officials (Unaudited): The University concurs with the finding and has made t the required corrections to the COD disbursement dates. The University process when posting Aid has remained consistent each year, this appears to be an isolated incident where CAMS did not pick up the date listed on the disbursement screen for these students and pass that to COD. The University has implemented a control to complete the disbursements each time and then verify the date reflects correctly in COD afterwards. While this should be an automatic process, and has been in previous years, it will be something the University verifies now with each aid posting.
Completion Date: August 2024
Contact Person: Megan Morton, Director of Financial Services