Information on the Federal Program: Student Financial Assistance Cluster; SEOG (ALN 84.007),PELL (ALN 84.063), and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Noncompliance.
Criteria:
1) 34 CFR 668.21 requires that if a student does not begin attendance in a period of enrollment, the institution must return those funds as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
2) 34 CFR 668.61 requires that, if an institution discovers that an applicant received more financial aid than eligible for, the program must be reimbursed by the earlier of the last day of the award year or sixty days after the applicant’s last day of attendance.
3) 34 CFR 668.22(j) requires that an institution return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Condition: Funds were not returned to the respective programs in the required timeframe.
Context:
1) Awards for students not enrolled: 9 out of a population of 12, ranging from 6 to 11 days past the 30-day deadline, amounting to $12,953.
2) Awards for students who withdrew: 5 out of a population of 7; ranging from 58 to 315 days past the 45-day deadline, amounting to $14,067.
3) Over-awards: 12 out of a population of 20; ranging from 46 to 222 days past the year-end/60-day deadline, amounting to $26,680.
Cause: Inadequate training in the Ellucian software system to timely identify students not enrolled, withdrawn, and over-awarded aid.
Effect or Potential Effect: The University could retain use of federal funds longer than the permissible timeframe. Students could receive SFA benefits in error.
Recommendation: Provide training to financial aid personnel on the federal return requirements and on the software system capabilities that identify student status and eligibility amounts.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; PELL (ALN 84.063) and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Noncompliance.
Criteria: The PELL and Direct Loan programs (Pell, 34 CFR section 690.83(b)(2) and Direct Loan, 34 CFR section 685.309) require institutions to submit enrollment data and enrollment changes to the National Student Loan Data System (NSLDS).
Condition: SWAU submitted none of the required reporting to NSLDS for the 2023-24 year.
Context: Twelve reports were due for 2023-24, based on the NSLDS information reviewed during the audit. These delinquencies ranged from 180 to 459 days past due as of November 26, 2024.
Cause: A change in personnel and lack of timely hiring, understaffing and proper training in
the Registrar’s office and a new university student information system led to the reports not being generated and filed as required.
Effect or Potential Effect: Student enrollment status is not correctly reflected in the NSLDS system, potentially allowing students to not begin loan repayment in the correct timeframe.
Recommendation: The delinquent NSLDS reports for the 2023-24 academic year were subsequently prepared and submitted as of February 11, 2025. Staffing has been added. Deadlines and clear responsibilities for duties and tasks should be communicated and training provided if needed, to avoid recurrence.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; PELL (ALN 84.063) and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Noncompliance.
Criteria: The PELL and Direct Loan programs (Pell, 34 CFR section 690.83(b)(2) and Direct Loan, 34 CFR section 685.309) require institutions to submit enrollment data and enrollment changes to the National Student Loan Data System (NSLDS).
Condition: SWAU submitted none of the required reporting to NSLDS for the 2023-24 year.
Context: Twelve reports were due for 2023-24, based on the NSLDS information reviewed during the audit. These delinquencies ranged from 180 to 459 days past due as of November 26, 2024.
Cause: A change in personnel and lack of timely hiring, understaffing and proper training in
the Registrar’s office and a new university student information system led to the reports not being generated and filed as required.
Effect or Potential Effect: Student enrollment status is not correctly reflected in the NSLDS system, potentially allowing students to not begin loan repayment in the correct timeframe.
Recommendation: The delinquent NSLDS reports for the 2023-24 academic year were subsequently prepared and submitted as of February 11, 2025. Staffing has been added. Deadlines and clear responsibilities for duties and tasks should be communicated and training provided if needed, to avoid recurrence.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; SEOG (ALN 84.007),PELL (ALN 84.063), and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Noncompliance.
Criteria:
1) 34 CFR 668.21 requires that if a student does not begin attendance in a period of enrollment, the institution must return those funds as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
2) 34 CFR 668.61 requires that, if an institution discovers that an applicant received more financial aid than eligible for, the program must be reimbursed by the earlier of the last day of the award year or sixty days after the applicant’s last day of attendance.
3) 34 CFR 668.22(j) requires that an institution return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Condition: Funds were not returned to the respective programs in the required timeframe.
Context:
1) Awards for students not enrolled: 9 out of a population of 12, ranging from 6 to 11 days past the 30-day deadline, amounting to $12,953.
2) Awards for students who withdrew: 5 out of a population of 7; ranging from 58 to 315 days past the 45-day deadline, amounting to $14,067.
3) Over-awards: 12 out of a population of 20; ranging from 46 to 222 days past the year-end/60-day deadline, amounting to $26,680.
Cause: Inadequate training in the Ellucian software system to timely identify students not enrolled, withdrawn, and over-awarded aid.
Effect or Potential Effect: The University could retain use of federal funds longer than the permissible timeframe. Students could receive SFA benefits in error.
Recommendation: Provide training to financial aid personnel on the federal return requirements and on the software system capabilities that identify student status and eligibility amounts.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; SEOG (ALN 84.007),PELL (ALN 84.063), and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Noncompliance.
Criteria:
1) 34 CFR 668.21 requires that if a student does not begin attendance in a period of enrollment, the institution must return those funds as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
2) 34 CFR 668.61 requires that, if an institution discovers that an applicant received more financial aid than eligible for, the program must be reimbursed by the earlier of the last day of the award year or sixty days after the applicant’s last day of attendance.
3) 34 CFR 668.22(j) requires that an institution return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Condition: Funds were not returned to the respective programs in the required timeframe.
Context:
1) Awards for students not enrolled: 9 out of a population of 12, ranging from 6 to 11 days past the 30-day deadline, amounting to $12,953.
2) Awards for students who withdrew: 5 out of a population of 7; ranging from 58 to 315 days past the 45-day deadline, amounting to $14,067.
3) Over-awards: 12 out of a population of 20; ranging from 46 to 222 days past the year-end/60-day deadline, amounting to $26,680.
Cause: Inadequate training in the Ellucian software system to timely identify students not enrolled, withdrawn, and over-awarded aid.
Effect or Potential Effect: The University could retain use of federal funds longer than the permissible timeframe. Students could receive SFA benefits in error.
Recommendation: Provide training to financial aid personnel on the federal return requirements and on the software system capabilities that identify student status and eligibility amounts.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; SEOG (ALN 84.007),PELL (ALN 84.063), and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Material Weakness in Internal Control over Compliance.
Criteria: Institutions should have proper internal controls in place to ensure compliance with the NSLDS reporting requirements of 34 CFR section 690.83(b)(2) and 34 CFR section 685.309 and with the timely return of Title IV funds under 34 CFR 668.21, 34 CFR 668.61, and 34 CFR 668.22(j).
Condition: Lack of appropriate internal controls over compliance allowed for the findings noted in 2024-001 and 2024-002 above.
Context: These errors affected twelve NSLDS reports and all students that withdrew or graduated during the year, as well as twenty-six students that either didn’t enroll, withdrew, or were over-awarded aid.
Cause: Inadequate oversight to ensure compliance with these SFA requirements, due to inadequate staffing and continued difficulties with the Ellucian software system.
Effect or Possible Effect: Students could be allowed to not begin loan repayment when required. University could retain funds improperly. Other errors could occur.
Recommendation: Follow recommendations noted above in 2024-001 and 2024-002.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; SEOG (ALN 84.007),PELL (ALN 84.063), and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Material Weakness in Internal Control over Compliance.
Criteria: Institutions should have proper internal controls in place to ensure compliance with the NSLDS reporting requirements of 34 CFR section 690.83(b)(2) and 34 CFR section 685.309 and with the timely return of Title IV funds under 34 CFR 668.21, 34 CFR 668.61, and 34 CFR 668.22(j).
Condition: Lack of appropriate internal controls over compliance allowed for the findings noted in 2024-001 and 2024-002 above.
Context: These errors affected twelve NSLDS reports and all students that withdrew or graduated during the year, as well as twenty-six students that either didn’t enroll, withdrew, or were over-awarded aid.
Cause: Inadequate oversight to ensure compliance with these SFA requirements, due to inadequate staffing and continued difficulties with the Ellucian software system.
Effect or Possible Effect: Students could be allowed to not begin loan repayment when required. University could retain funds improperly. Other errors could occur.
Recommendation: Follow recommendations noted above in 2024-001 and 2024-002.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; SEOG (ALN 84.007),PELL (ALN 84.063), and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Material Weakness in Internal Control over Compliance.
Criteria: Institutions should have proper internal controls in place to ensure compliance with the NSLDS reporting requirements of 34 CFR section 690.83(b)(2) and 34 CFR section 685.309 and with the timely return of Title IV funds under 34 CFR 668.21, 34 CFR 668.61, and 34 CFR 668.22(j).
Condition: Lack of appropriate internal controls over compliance allowed for the findings noted in 2024-001 and 2024-002 above.
Context: These errors affected twelve NSLDS reports and all students that withdrew or graduated during the year, as well as twenty-six students that either didn’t enroll, withdrew, or were over-awarded aid.
Cause: Inadequate oversight to ensure compliance with these SFA requirements, due to inadequate staffing and continued difficulties with the Ellucian software system.
Effect or Possible Effect: Students could be allowed to not begin loan repayment when required. University could retain funds improperly. Other errors could occur.
Recommendation: Follow recommendations noted above in 2024-001 and 2024-002.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; SEOG (ALN 84.007),PELL (ALN 84.063), and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Noncompliance.
Criteria:
1) 34 CFR 668.21 requires that if a student does not begin attendance in a period of enrollment, the institution must return those funds as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
2) 34 CFR 668.61 requires that, if an institution discovers that an applicant received more financial aid than eligible for, the program must be reimbursed by the earlier of the last day of the award year or sixty days after the applicant’s last day of attendance.
3) 34 CFR 668.22(j) requires that an institution return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Condition: Funds were not returned to the respective programs in the required timeframe.
Context:
1) Awards for students not enrolled: 9 out of a population of 12, ranging from 6 to 11 days past the 30-day deadline, amounting to $12,953.
2) Awards for students who withdrew: 5 out of a population of 7; ranging from 58 to 315 days past the 45-day deadline, amounting to $14,067.
3) Over-awards: 12 out of a population of 20; ranging from 46 to 222 days past the year-end/60-day deadline, amounting to $26,680.
Cause: Inadequate training in the Ellucian software system to timely identify students not enrolled, withdrawn, and over-awarded aid.
Effect or Potential Effect: The University could retain use of federal funds longer than the permissible timeframe. Students could receive SFA benefits in error.
Recommendation: Provide training to financial aid personnel on the federal return requirements and on the software system capabilities that identify student status and eligibility amounts.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; PELL (ALN 84.063) and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Noncompliance.
Criteria: The PELL and Direct Loan programs (Pell, 34 CFR section 690.83(b)(2) and Direct Loan, 34 CFR section 685.309) require institutions to submit enrollment data and enrollment changes to the National Student Loan Data System (NSLDS).
Condition: SWAU submitted none of the required reporting to NSLDS for the 2023-24 year.
Context: Twelve reports were due for 2023-24, based on the NSLDS information reviewed during the audit. These delinquencies ranged from 180 to 459 days past due as of November 26, 2024.
Cause: A change in personnel and lack of timely hiring, understaffing and proper training in
the Registrar’s office and a new university student information system led to the reports not being generated and filed as required.
Effect or Potential Effect: Student enrollment status is not correctly reflected in the NSLDS system, potentially allowing students to not begin loan repayment in the correct timeframe.
Recommendation: The delinquent NSLDS reports for the 2023-24 academic year were subsequently prepared and submitted as of February 11, 2025. Staffing has been added. Deadlines and clear responsibilities for duties and tasks should be communicated and training provided if needed, to avoid recurrence.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; PELL (ALN 84.063) and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Noncompliance.
Criteria: The PELL and Direct Loan programs (Pell, 34 CFR section 690.83(b)(2) and Direct Loan, 34 CFR section 685.309) require institutions to submit enrollment data and enrollment changes to the National Student Loan Data System (NSLDS).
Condition: SWAU submitted none of the required reporting to NSLDS for the 2023-24 year.
Context: Twelve reports were due for 2023-24, based on the NSLDS information reviewed during the audit. These delinquencies ranged from 180 to 459 days past due as of November 26, 2024.
Cause: A change in personnel and lack of timely hiring, understaffing and proper training in
the Registrar’s office and a new university student information system led to the reports not being generated and filed as required.
Effect or Potential Effect: Student enrollment status is not correctly reflected in the NSLDS system, potentially allowing students to not begin loan repayment in the correct timeframe.
Recommendation: The delinquent NSLDS reports for the 2023-24 academic year were subsequently prepared and submitted as of February 11, 2025. Staffing has been added. Deadlines and clear responsibilities for duties and tasks should be communicated and training provided if needed, to avoid recurrence.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; SEOG (ALN 84.007),PELL (ALN 84.063), and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Noncompliance.
Criteria:
1) 34 CFR 668.21 requires that if a student does not begin attendance in a period of enrollment, the institution must return those funds as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
2) 34 CFR 668.61 requires that, if an institution discovers that an applicant received more financial aid than eligible for, the program must be reimbursed by the earlier of the last day of the award year or sixty days after the applicant’s last day of attendance.
3) 34 CFR 668.22(j) requires that an institution return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Condition: Funds were not returned to the respective programs in the required timeframe.
Context:
1) Awards for students not enrolled: 9 out of a population of 12, ranging from 6 to 11 days past the 30-day deadline, amounting to $12,953.
2) Awards for students who withdrew: 5 out of a population of 7; ranging from 58 to 315 days past the 45-day deadline, amounting to $14,067.
3) Over-awards: 12 out of a population of 20; ranging from 46 to 222 days past the year-end/60-day deadline, amounting to $26,680.
Cause: Inadequate training in the Ellucian software system to timely identify students not enrolled, withdrawn, and over-awarded aid.
Effect or Potential Effect: The University could retain use of federal funds longer than the permissible timeframe. Students could receive SFA benefits in error.
Recommendation: Provide training to financial aid personnel on the federal return requirements and on the software system capabilities that identify student status and eligibility amounts.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; SEOG (ALN 84.007),PELL (ALN 84.063), and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Noncompliance.
Criteria:
1) 34 CFR 668.21 requires that if a student does not begin attendance in a period of enrollment, the institution must return those funds as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
2) 34 CFR 668.61 requires that, if an institution discovers that an applicant received more financial aid than eligible for, the program must be reimbursed by the earlier of the last day of the award year or sixty days after the applicant’s last day of attendance.
3) 34 CFR 668.22(j) requires that an institution return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Condition: Funds were not returned to the respective programs in the required timeframe.
Context:
1) Awards for students not enrolled: 9 out of a population of 12, ranging from 6 to 11 days past the 30-day deadline, amounting to $12,953.
2) Awards for students who withdrew: 5 out of a population of 7; ranging from 58 to 315 days past the 45-day deadline, amounting to $14,067.
3) Over-awards: 12 out of a population of 20; ranging from 46 to 222 days past the year-end/60-day deadline, amounting to $26,680.
Cause: Inadequate training in the Ellucian software system to timely identify students not enrolled, withdrawn, and over-awarded aid.
Effect or Potential Effect: The University could retain use of federal funds longer than the permissible timeframe. Students could receive SFA benefits in error.
Recommendation: Provide training to financial aid personnel on the federal return requirements and on the software system capabilities that identify student status and eligibility amounts.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; SEOG (ALN 84.007),PELL (ALN 84.063), and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Material Weakness in Internal Control over Compliance.
Criteria: Institutions should have proper internal controls in place to ensure compliance with the NSLDS reporting requirements of 34 CFR section 690.83(b)(2) and 34 CFR section 685.309 and with the timely return of Title IV funds under 34 CFR 668.21, 34 CFR 668.61, and 34 CFR 668.22(j).
Condition: Lack of appropriate internal controls over compliance allowed for the findings noted in 2024-001 and 2024-002 above.
Context: These errors affected twelve NSLDS reports and all students that withdrew or graduated during the year, as well as twenty-six students that either didn’t enroll, withdrew, or were over-awarded aid.
Cause: Inadequate oversight to ensure compliance with these SFA requirements, due to inadequate staffing and continued difficulties with the Ellucian software system.
Effect or Possible Effect: Students could be allowed to not begin loan repayment when required. University could retain funds improperly. Other errors could occur.
Recommendation: Follow recommendations noted above in 2024-001 and 2024-002.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; SEOG (ALN 84.007),PELL (ALN 84.063), and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Material Weakness in Internal Control over Compliance.
Criteria: Institutions should have proper internal controls in place to ensure compliance with the NSLDS reporting requirements of 34 CFR section 690.83(b)(2) and 34 CFR section 685.309 and with the timely return of Title IV funds under 34 CFR 668.21, 34 CFR 668.61, and 34 CFR 668.22(j).
Condition: Lack of appropriate internal controls over compliance allowed for the findings noted in 2024-001 and 2024-002 above.
Context: These errors affected twelve NSLDS reports and all students that withdrew or graduated during the year, as well as twenty-six students that either didn’t enroll, withdrew, or were over-awarded aid.
Cause: Inadequate oversight to ensure compliance with these SFA requirements, due to inadequate staffing and continued difficulties with the Ellucian software system.
Effect or Possible Effect: Students could be allowed to not begin loan repayment when required. University could retain funds improperly. Other errors could occur.
Recommendation: Follow recommendations noted above in 2024-001 and 2024-002.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.
Information on the Federal Program: Student Financial Assistance Cluster; SEOG (ALN 84.007),PELL (ALN 84.063), and Direct Loans (ALN 84.268); United States Department of Education; Award Year 2023-24; Compliance requirement – Special Tests and Provisions; Type of Finding: Material Weakness in Internal Control over Compliance.
Criteria: Institutions should have proper internal controls in place to ensure compliance with the NSLDS reporting requirements of 34 CFR section 690.83(b)(2) and 34 CFR section 685.309 and with the timely return of Title IV funds under 34 CFR 668.21, 34 CFR 668.61, and 34 CFR 668.22(j).
Condition: Lack of appropriate internal controls over compliance allowed for the findings noted in 2024-001 and 2024-002 above.
Context: These errors affected twelve NSLDS reports and all students that withdrew or graduated during the year, as well as twenty-six students that either didn’t enroll, withdrew, or were over-awarded aid.
Cause: Inadequate oversight to ensure compliance with these SFA requirements, due to inadequate staffing and continued difficulties with the Ellucian software system.
Effect or Possible Effect: Students could be allowed to not begin loan repayment when required. University could retain funds improperly. Other errors could occur.
Recommendation: Follow recommendations noted above in 2024-001 and 2024-002.
Responsible Official’s Response and Corrective Action Planned: See corrective action plan.