Criteria or specific requirement: Per 34 CFR 668.164(l)(3), if a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check.
Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial assistance regulation requirement that any Title IV federal funds disbursed must be returned to the appropriate federal financial assistance program no later than 240 days after the check was issued if not cashed by the intended recipient.
Questioned costs: N/A
Context: During our testing of the 240-day requirement of 40 disbursements, we noted that two outstanding checks issued to a student or parent were cancelled by the University and returned to the Department of Education beyond the 240 day requirement – one was returned to the Department 267 days after the check was issued and the second was returned to the Department 257 days after the check was issued.
Cause: The University did not have adequate processes in place to monitor outstanding Title IV disbursement checks throughout the year.
Effect: The University is not in compliance with Department of Education requirements.
Repeat finding: No
Recommendation: CLA recommends that the University review the requirement and implement a control to monitor outstanding checks throughout the year to ensure outstanding checks are returned to the Department of Education in accordance with time requirements.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 668.164(l)(3), if a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check.
Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial assistance regulation requirement that any Title IV federal funds disbursed must be returned to the appropriate federal financial assistance program no later than 240 days after the check was issued if not cashed by the intended recipient.
Questioned costs: N/A
Context: During our testing of the 240-day requirement of 40 disbursements, we noted that two outstanding checks issued to a student or parent were cancelled by the University and returned to the Department of Education beyond the 240 day requirement – one was returned to the Department 267 days after the check was issued and the second was returned to the Department 257 days after the check was issued.
Cause: The University did not have adequate processes in place to monitor outstanding Title IV disbursement checks throughout the year.
Effect: The University is not in compliance with Department of Education requirements.
Repeat finding: No
Recommendation: CLA recommends that the University review the requirement and implement a control to monitor outstanding checks throughout the year to ensure outstanding checks are returned to the Department of Education in accordance with time requirements.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 690.83(b)(2) and 685.309, an institution must report any enrollment status changes, including the date of the change per the institution’s reporting system, to the National Student Loan Data System (NSLDS) for participating students within 60 days of the change. Per the NSLDS Enrollment Reporting Guide Chapter 1.4, at a minimum, schools are required to certify enrollment every 60 days.
Condition: As part of the May 3, 2024, roster submission of enrollment status changes, the University reported an enrollment status change of Half-Time to Full-Time with an effective date of September 26, 2023 for a student who received both a Federal Pell Grant and Direct Student Loan during the fiscal year. The University reported the enrollment status change for this student 220 days after the effective date. Additionally, per the University’s enrollment records, this student was enrolled at the University during Fall Term 2023 and Winter Term 2024 but was not certified as enrolled in NSLDS as required every 60 days.
Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment status change was not reported within 60 days and whose enrollment was not being certified every 60 days.
Questioned costs: None
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Title IV Student Financial Aid program.
Effect: Enrollment reporting assists lenders in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status.
Repeat Finding: Yes
Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 days.
Views of responsible officials: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 690.83(b)(2) and 685.309, an institution must report any enrollment status changes, including the date of the change per the institution’s reporting system, to the National Student Loan Data System (NSLDS) for participating students within 60 days of the change. Per the NSLDS Enrollment Reporting Guide Chapter 1.4, at a minimum, schools are required to certify enrollment every 60 days.
Condition: As part of the May 3, 2024, roster submission of enrollment status changes, the University reported an enrollment status change of Half-Time to Full-Time with an effective date of September 26, 2023 for a student who received both a Federal Pell Grant and Direct Student Loan during the fiscal year. The University reported the enrollment status change for this student 220 days after the effective date. Additionally, per the University’s enrollment records, this student was enrolled at the University during Fall Term 2023 and Winter Term 2024 but was not certified as enrolled in NSLDS as required every 60 days.
Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment status change was not reported within 60 days and whose enrollment was not being certified every 60 days.
Questioned costs: None
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Title IV Student Financial Aid program.
Effect: Enrollment reporting assists lenders in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status.
Repeat Finding: Yes
Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 days.
Views of responsible officials: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 668.164(l)(3), if a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check.
Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial assistance regulation requirement that any Title IV federal funds disbursed must be returned to the appropriate federal financial assistance program no later than 240 days after the check was issued if not cashed by the intended recipient.
Questioned costs: N/A
Context: During our testing of the 240-day requirement of 40 disbursements, we noted that two outstanding checks issued to a student or parent were cancelled by the University and returned to the Department of Education beyond the 240 day requirement – one was returned to the Department 267 days after the check was issued and the second was returned to the Department 257 days after the check was issued.
Cause: The University did not have adequate processes in place to monitor outstanding Title IV disbursement checks throughout the year.
Effect: The University is not in compliance with Department of Education requirements.
Repeat finding: No
Recommendation: CLA recommends that the University review the requirement and implement a control to monitor outstanding checks throughout the year to ensure outstanding checks are returned to the Department of Education in accordance with time requirements.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 668.164(l)(3), if a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check.
Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial assistance regulation requirement that any Title IV federal funds disbursed must be returned to the appropriate federal financial assistance program no later than 240 days after the check was issued if not cashed by the intended recipient.
Questioned costs: N/A
Context: During our testing of the 240-day requirement of 40 disbursements, we noted that two outstanding checks issued to a student or parent were cancelled by the University and returned to the Department of Education beyond the 240 day requirement – one was returned to the Department 267 days after the check was issued and the second was returned to the Department 257 days after the check was issued.
Cause: The University did not have adequate processes in place to monitor outstanding Title IV disbursement checks throughout the year.
Effect: The University is not in compliance with Department of Education requirements.
Repeat finding: No
Recommendation: CLA recommends that the University review the requirement and implement a control to monitor outstanding checks throughout the year to ensure outstanding checks are returned to the Department of Education in accordance with time requirements.
View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 690.83(b)(2) and 685.309, an institution must report any enrollment status changes, including the date of the change per the institution’s reporting system, to the National Student Loan Data System (NSLDS) for participating students within 60 days of the change. Per the NSLDS Enrollment Reporting Guide Chapter 1.4, at a minimum, schools are required to certify enrollment every 60 days.
Condition: As part of the May 3, 2024, roster submission of enrollment status changes, the University reported an enrollment status change of Half-Time to Full-Time with an effective date of September 26, 2023 for a student who received both a Federal Pell Grant and Direct Student Loan during the fiscal year. The University reported the enrollment status change for this student 220 days after the effective date. Additionally, per the University’s enrollment records, this student was enrolled at the University during Fall Term 2023 and Winter Term 2024 but was not certified as enrolled in NSLDS as required every 60 days.
Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment status change was not reported within 60 days and whose enrollment was not being certified every 60 days.
Questioned costs: None
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Title IV Student Financial Aid program.
Effect: Enrollment reporting assists lenders in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status.
Repeat Finding: Yes
Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 days.
Views of responsible officials: The University agrees with the finding.
Criteria or specific requirement: Per 34 CFR 690.83(b)(2) and 685.309, an institution must report any enrollment status changes, including the date of the change per the institution’s reporting system, to the National Student Loan Data System (NSLDS) for participating students within 60 days of the change. Per the NSLDS Enrollment Reporting Guide Chapter 1.4, at a minimum, schools are required to certify enrollment every 60 days.
Condition: As part of the May 3, 2024, roster submission of enrollment status changes, the University reported an enrollment status change of Half-Time to Full-Time with an effective date of September 26, 2023 for a student who received both a Federal Pell Grant and Direct Student Loan during the fiscal year. The University reported the enrollment status change for this student 220 days after the effective date. Additionally, per the University’s enrollment records, this student was enrolled at the University during Fall Term 2023 and Winter Term 2024 but was not certified as enrolled in NSLDS as required every 60 days.
Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment status change was not reported within 60 days and whose enrollment was not being certified every 60 days.
Questioned costs: None
Cause: The University did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Title IV Student Financial Aid program.
Effect: Enrollment reporting assists lenders in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status.
Repeat Finding: Yes
Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 days.
Views of responsible officials: The University agrees with the finding.