Federal Program: Student Financial Assistance Cluster (ALN: 84.007, 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): C. Cash Management - An institution submits a drawdown
request for funds utilizing ED’s electronic grants management system, known as G5, that may not exceed the amount of fundsneeded to make immediate disbursements to eligible students and parents. If the request is accepted, ED initiates an electronic funds transfer to the institution’s account. The
institution must then disburse the requested funds no later than three business days following receipt of those funds from ED. For institutions on the Advance Payment Method, any amount of Title IV funds not disbursed to recipients by the end of the third business day is considered excess cash. ED allows an institution
to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to ED any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold.
Condition: The University retained excess cash for a period greater than the tolerance period three times during the year.
Cause: Insufficient administrative oversight with respect to cash management compliance requirements.
Effect or Potential Effect: The University is not in compliance with cash management
compliance requirements.
Questioned Costs: None.
Context: Three instances during the year where excess cash was retained longer than the tolerance period.
Identification as a Repeat Finding: There was not a similar finding identified in the prior year.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of cash management to ensure that excess cash is returned timely.
Views of Responsible Officials and Planned Corrective Actions:
To prevent similar occurrences in the future, we will transition from monthly program reconciliations to weekly FSEOG reconciliations and bi-weekly Federal Work Study reconciliations, which will allow for more effective monitoring of award reversals or negative adjustments. Upon completion of these reconciliations, any excess cash identified will be promptly returned via G-5. Additionally, we will explore the feasibility of automating the notification process for negative adjustments posted in the ERP system, ensuring that we can capture excess cash in a more timely manner.
Federal Program: Student Financial Assistance Cluster (ALN: 84.007, 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): C. Cash Management - An institution submits a drawdown
request for funds utilizing ED’s electronic grants management system, known as G5, that may not exceed the amount of fundsneeded to make immediate disbursements to eligible students and parents. If the request is accepted, ED initiates an electronic funds transfer to the institution’s account. The
institution must then disburse the requested funds no later than three business days following receipt of those funds from ED. For institutions on the Advance Payment Method, any amount of Title IV funds not disbursed to recipients by the end of the third business day is considered excess cash. ED allows an institution
to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to ED any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold.
Condition: The University retained excess cash for a period greater than the tolerance period three times during the year.
Cause: Insufficient administrative oversight with respect to cash management compliance requirements.
Effect or Potential Effect: The University is not in compliance with cash management
compliance requirements.
Questioned Costs: None.
Context: Three instances during the year where excess cash was retained longer than the tolerance period.
Identification as a Repeat Finding: There was not a similar finding identified in the prior year.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of cash management to ensure that excess cash is returned timely.
Views of Responsible Officials and Planned Corrective Actions:
To prevent similar occurrences in the future, we will transition from monthly program reconciliations to weekly FSEOG reconciliations and bi-weekly Federal Work Study reconciliations, which will allow for more effective monitoring of award reversals or negative adjustments. Upon completion of these reconciliations, any excess cash identified will be promptly returned via G-5. Additionally, we will explore the feasibility of automating the notification process for negative adjustments posted in the ERP system, ensuring that we can capture excess cash in a more timely manner.
Federal Program: Student Financial Assistance Cluster (ALN: Various) Criteria or Specific Requirement
(Including Statutory, Regulatory or Other Citation):
N. Enrollment Reporting - The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 60 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a thirdparty
servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: For 2 of 40 students sampled whose status changed during the
fiscal year, the University failed to report an accurate enrollment status. For 5 of 40 students sampled whose status changed during the fiscal year, the University failed to report the enrollment status within the required timeframe.
Cause: Insufficient administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: The University did not submit an accurate or timely status change notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2023-004 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University has implemented several corrective actions to address this finding. We have created a comprehensive process document to ensure accurate reporting of student enrollment changes. This document outlines each step of the reporting process in detail, providing clear guidelines and procedures for staff to follow for each type of enrollment report that is required. This document will also outline a procedure for conducting reviews of student status changes to ensure they align with our reported data. These reviews will involve crosschecking the information in our reporting system with data generated by our student information system’s delivered enrollment reporting process to identify discrepancies prior to submitting the report. Additionally, we are seeking training and outside consultation on how to better utilize our student information system more effectively. We will engage with consultants to improve our student information system’s delivered student withdrawal and enrollment reporting processes. By utilizing our student information system’s delivered processes more effectively, we will reduce future enrollment reporting errors.
Federal Program: Student Financial Assistance Cluster (ALN: Various) Criteria or Specific Requirement
(Including Statutory, Regulatory or Other Citation):
N. Enrollment Reporting - The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 60 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a thirdparty
servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: For 2 of 40 students sampled whose status changed during the
fiscal year, the University failed to report an accurate enrollment status. For 5 of 40 students sampled whose status changed during the fiscal year, the University failed to report the enrollment status within the required timeframe.
Cause: Insufficient administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: The University did not submit an accurate or timely status change notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2023-004 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University has implemented several corrective actions to address this finding. We have created a comprehensive process document to ensure accurate reporting of student enrollment changes. This document outlines each step of the reporting process in detail, providing clear guidelines and procedures for staff to follow for each type of enrollment report that is required. This document will also outline a procedure for conducting reviews of student status changes to ensure they align with our reported data. These reviews will involve crosschecking the information in our reporting system with data generated by our student information system’s delivered enrollment reporting process to identify discrepancies prior to submitting the report. Additionally, we are seeking training and outside consultation on how to better utilize our student information system more effectively. We will engage with consultants to improve our student information system’s delivered student withdrawal and enrollment reporting processes. By utilizing our student information system’s delivered processes more effectively, we will reduce future enrollment reporting errors.
Federal Program: Student Financial Assistance Cluster (ALN: 84.007, 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): C. Cash Management - An institution submits a drawdown
request for funds utilizing ED’s electronic grants management system, known as G5, that may not exceed the amount of fundsneeded to make immediate disbursements to eligible students and parents. If the request is accepted, ED initiates an electronic funds transfer to the institution’s account. The
institution must then disburse the requested funds no later than three business days following receipt of those funds from ED. For institutions on the Advance Payment Method, any amount of Title IV funds not disbursed to recipients by the end of the third business day is considered excess cash. ED allows an institution
to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to ED any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold.
Condition: The University retained excess cash for a period greater than the tolerance period three times during the year.
Cause: Insufficient administrative oversight with respect to cash management compliance requirements.
Effect or Potential Effect: The University is not in compliance with cash management
compliance requirements.
Questioned Costs: None.
Context: Three instances during the year where excess cash was retained longer than the tolerance period.
Identification as a Repeat Finding: There was not a similar finding identified in the prior year.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of cash management to ensure that excess cash is returned timely.
Views of Responsible Officials and Planned Corrective Actions:
To prevent similar occurrences in the future, we will transition from monthly program reconciliations to weekly FSEOG reconciliations and bi-weekly Federal Work Study reconciliations, which will allow for more effective monitoring of award reversals or negative adjustments. Upon completion of these reconciliations, any excess cash identified will be promptly returned via G-5. Additionally, we will explore the feasibility of automating the notification process for negative adjustments posted in the ERP system, ensuring that we can capture excess cash in a more timely manner.
Federal Program: Student Financial Assistance Cluster (ALN: 84.007, 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): C. Cash Management - An institution submits a drawdown
request for funds utilizing ED’s electronic grants management system, known as G5, that may not exceed the amount of fundsneeded to make immediate disbursements to eligible students and parents. If the request is accepted, ED initiates an electronic funds transfer to the institution’s account. The
institution must then disburse the requested funds no later than three business days following receipt of those funds from ED. For institutions on the Advance Payment Method, any amount of Title IV funds not disbursed to recipients by the end of the third business day is considered excess cash. ED allows an institution
to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to ED any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold.
Condition: The University retained excess cash for a period greater than the tolerance period three times during the year.
Cause: Insufficient administrative oversight with respect to cash management compliance requirements.
Effect or Potential Effect: The University is not in compliance with cash management
compliance requirements.
Questioned Costs: None.
Context: Three instances during the year where excess cash was retained longer than the tolerance period.
Identification as a Repeat Finding: There was not a similar finding identified in the prior year.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of cash management to ensure that excess cash is returned timely.
Views of Responsible Officials and Planned Corrective Actions:
To prevent similar occurrences in the future, we will transition from monthly program reconciliations to weekly FSEOG reconciliations and bi-weekly Federal Work Study reconciliations, which will allow for more effective monitoring of award reversals or negative adjustments. Upon completion of these reconciliations, any excess cash identified will be promptly returned via G-5. Additionally, we will explore the feasibility of automating the notification process for negative adjustments posted in the ERP system, ensuring that we can capture excess cash in a more timely manner.
Federal Program: Student Financial Assistance Cluster (ALN: Various) Criteria or Specific Requirement
(Including Statutory, Regulatory or Other Citation):
N. Enrollment Reporting - The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 60 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a thirdparty
servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: For 2 of 40 students sampled whose status changed during the
fiscal year, the University failed to report an accurate enrollment status. For 5 of 40 students sampled whose status changed during the fiscal year, the University failed to report the enrollment status within the required timeframe.
Cause: Insufficient administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: The University did not submit an accurate or timely status change notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2023-004 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University has implemented several corrective actions to address this finding. We have created a comprehensive process document to ensure accurate reporting of student enrollment changes. This document outlines each step of the reporting process in detail, providing clear guidelines and procedures for staff to follow for each type of enrollment report that is required. This document will also outline a procedure for conducting reviews of student status changes to ensure they align with our reported data. These reviews will involve crosschecking the information in our reporting system with data generated by our student information system’s delivered enrollment reporting process to identify discrepancies prior to submitting the report. Additionally, we are seeking training and outside consultation on how to better utilize our student information system more effectively. We will engage with consultants to improve our student information system’s delivered student withdrawal and enrollment reporting processes. By utilizing our student information system’s delivered processes more effectively, we will reduce future enrollment reporting errors.
Federal Program: Student Financial Assistance Cluster (ALN: Various) Criteria or Specific Requirement
(Including Statutory, Regulatory or Other Citation):
N. Enrollment Reporting - The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 60 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a thirdparty
servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: For 2 of 40 students sampled whose status changed during the
fiscal year, the University failed to report an accurate enrollment status. For 5 of 40 students sampled whose status changed during the fiscal year, the University failed to report the enrollment status within the required timeframe.
Cause: Insufficient administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: The University did not submit an accurate or timely status change notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2023-004 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The University has implemented several corrective actions to address this finding. We have created a comprehensive process document to ensure accurate reporting of student enrollment changes. This document outlines each step of the reporting process in detail, providing clear guidelines and procedures for staff to follow for each type of enrollment report that is required. This document will also outline a procedure for conducting reviews of student status changes to ensure they align with our reported data. These reviews will involve crosschecking the information in our reporting system with data generated by our student information system’s delivered enrollment reporting process to identify discrepancies prior to submitting the report. Additionally, we are seeking training and outside consultation on how to better utilize our student information system more effectively. We will engage with consultants to improve our student information system’s delivered student withdrawal and enrollment reporting processes. By utilizing our student information system’s delivered processes more effectively, we will reduce future enrollment reporting errors.