2024-004
8540.032
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. "
The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
N/A
"During our testing of 9 students, we identified 4 students whose enrollment status changes were not reported, 1 student with an incorrect effective date reported, 1 student with an incorrect program begin date, and 6 students whose status changes were not reported timely. In addition, 1 student was incorrectly reported as withdrawal who should not have had a status change reported. We also note that for 7 of the selected students, enrollment status was not certified every 60 days.
We also note that the University did not document any evidence of review."
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Yes
We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Management agrees with this finding.
See 0100.25
2024-004
8540.032
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. "
The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
N/A
"During our testing of 9 students, we identified 4 students whose enrollment status changes were not reported, 1 student with an incorrect effective date reported, 1 student with an incorrect program begin date, and 6 students whose status changes were not reported timely. In addition, 1 student was incorrectly reported as withdrawal who should not have had a status change reported. We also note that for 7 of the selected students, enrollment status was not certified every 60 days.
We also note that the University did not document any evidence of review."
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Yes
We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Management agrees with this finding.
See 0100.25
2024-005
8540.10
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Material Weakness
Material
Appears to be systemic.
"34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations.
283.39
"During our testing of 6 R2T4 calculations, we noted that 4 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 4 students, all 4 should have had an R2T4 calculation, and 2 should have had returned funds. In addition, we observed 1 student for whom 100% of funds were returned despite the student completing a portion of the term. We also noted 1 student who completed the term with passing grades for whom an R2T4 calculation was completed, and funds were returned in error.
Additionally, R2T4 calculations did not have documentation of review."
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned.
No
We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Management agrees with this finding.
See 0100.25
2024-005
8540.10
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Material Weakness
Material
Appears to be systemic.
"34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations.
283.39
"During our testing of 6 R2T4 calculations, we noted that 4 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 4 students, all 4 should have had an R2T4 calculation, and 2 should have had returned funds. In addition, we observed 1 student for whom 100% of funds were returned despite the student completing a portion of the term. We also noted 1 student who completed the term with passing grades for whom an R2T4 calculation was completed, and funds were returned in error.
Additionally, R2T4 calculations did not have documentation of review."
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned.
No
We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Management agrees with this finding.
See 0100.25
2024-006
8540.13
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementting your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution's written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
"The College has a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, we were unable to observe evidence that the WISP was formally reviewed and approved.
"
N/A
"The WISP was missing the element discussing the secure disposal of customer information. Additionally, there was not am observable formal review or authorization.
"
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
There is a risk the College’s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner.
Yes
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-006
8540.13
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementting your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution's written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
"The College has a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, we were unable to observe evidence that the WISP was formally reviewed and approved.
"
N/A
"The WISP was missing the element discussing the secure disposal of customer information. Additionally, there was not am observable formal review or authorization.
"
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
There is a risk the College’s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner.
Yes
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-007
8515.01
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Per 34 CFR 690.62 states the Pell grant for an academic year is based
upon the payment and disbursement schedule published by the Secretary for each award year.
34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance."
The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, the University did not notify 3 students of required exit counseling. The University also incorrectly disbursed Pell funds for 4 students.
1845
E
During our eligibility testing of 60 students, we noted that the university did not document evidence of review for controls performed by their third party servicer. The University did not document review of award packaging, professional judgment determinations, COD reporting, or verification procedures. We also noted that 3 students were graduates or withdrawals but did not receive notifcation of required exit counseling. Additionally, out of 37 students receiving Pell, 3 were overawarded and 1 was underawarded. 1 student had an incorrect EFC used in their award packaging.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-007
8515.01
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Per 34 CFR 690.62 states the Pell grant for an academic year is based
upon the payment and disbursement schedule published by the Secretary for each award year.
34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance."
The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, the University did not notify 3 students of required exit counseling. The University also incorrectly disbursed Pell funds for 4 students.
1845
E
During our eligibility testing of 60 students, we noted that the university did not document evidence of review for controls performed by their third party servicer. The University did not document review of award packaging, professional judgment determinations, COD reporting, or verification procedures. We also noted that 3 students were graduates or withdrawals but did not receive notifcation of required exit counseling. Additionally, out of 37 students receiving Pell, 3 were overawarded and 1 was underawarded. 1 student had an incorrect EFC used in their award packaging.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-008
8540.17
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Six Title IV checks were observed during testing that were stale more than 240 days.
4333.85
The University had six stale Title IV checks greater than 240 days
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Funds are not returned to the Department of Education in a timely manner
No
We recommend that the University review policies and procedures related to student refund checks to ensure stale checks are returned to the Department of Education.
Management agrees with this finding.
See 0100.25
2024-008
8540.17
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Six Title IV checks were observed during testing that were stale more than 240 days.
4333.85
The University had six stale Title IV checks greater than 240 days
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Funds are not returned to the Department of Education in a timely manner
No
We recommend that the University review policies and procedures related to student refund checks to ensure stale checks are returned to the Department of Education.
Management agrees with this finding.
See 0100.25
2024-009
8565.02
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by an institution participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. An institution must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
The University did not have documentation that Direct Loan Reconciliation prepared by third-party servicer was reviewed.
N/A
During our testing we examined four months of direct loan reconciliations (August, December, March, & May). For all four, the University's third party servicer (Campus Ivy) performed preparation and review of the reconciliation; however, Urshan did not review the work of Campus Ivy or a SOC1 report.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-009
8565.02
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by an institution participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. An institution must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
The University did not have documentation that Direct Loan Reconciliation prepared by third-party servicer was reviewed.
N/A
During our testing we examined four months of direct loan reconciliations (August, December, March, & May). For all four, the University's third party servicer (Campus Ivy) performed preparation and review of the reconciliation; however, Urshan did not review the work of Campus Ivy or a SOC1 report.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-010
8540.15
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Control finding did not result in material questioned costs-therefore we will document as a SD.
N/A - I/C Finding Only
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, we were unable to observe evidence that the University reviewed cash drawdowns prepared by the third party processor.
N/A
During our testing of Credit Balance refunds, CLA observed that the University did not have documentation of formal review. Additionally, during our testing of Cash Management CLA observed two draws that we were unable to verify review occurred.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-010
8540.15
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Control finding did not result in material questioned costs-therefore we will document as a SD.
N/A - I/C Finding Only
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, we were unable to observe evidence that the University reviewed cash drawdowns prepared by the third party processor.
N/A
During our testing of Credit Balance refunds, CLA observed that the University did not have documentation of formal review. Additionally, during our testing of Cash Management CLA observed two draws that we were unable to verify review occurred.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-004
8540.032
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. "
The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
N/A
"During our testing of 9 students, we identified 4 students whose enrollment status changes were not reported, 1 student with an incorrect effective date reported, 1 student with an incorrect program begin date, and 6 students whose status changes were not reported timely. In addition, 1 student was incorrectly reported as withdrawal who should not have had a status change reported. We also note that for 7 of the selected students, enrollment status was not certified every 60 days.
We also note that the University did not document any evidence of review."
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Yes
We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Management agrees with this finding.
See 0100.25
2024-004
8540.032
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. "
The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
N/A
"During our testing of 9 students, we identified 4 students whose enrollment status changes were not reported, 1 student with an incorrect effective date reported, 1 student with an incorrect program begin date, and 6 students whose status changes were not reported timely. In addition, 1 student was incorrectly reported as withdrawal who should not have had a status change reported. We also note that for 7 of the selected students, enrollment status was not certified every 60 days.
We also note that the University did not document any evidence of review."
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Yes
We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Management agrees with this finding.
See 0100.25
2024-005
8540.10
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Material Weakness
Material
Appears to be systemic.
"34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations.
283.39
"During our testing of 6 R2T4 calculations, we noted that 4 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 4 students, all 4 should have had an R2T4 calculation, and 2 should have had returned funds. In addition, we observed 1 student for whom 100% of funds were returned despite the student completing a portion of the term. We also noted 1 student who completed the term with passing grades for whom an R2T4 calculation was completed, and funds were returned in error.
Additionally, R2T4 calculations did not have documentation of review."
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned.
No
We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Management agrees with this finding.
See 0100.25
2024-005
8540.10
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Material Weakness
Material
Appears to be systemic.
"34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations.
283.39
"During our testing of 6 R2T4 calculations, we noted that 4 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 4 students, all 4 should have had an R2T4 calculation, and 2 should have had returned funds. In addition, we observed 1 student for whom 100% of funds were returned despite the student completing a portion of the term. We also noted 1 student who completed the term with passing grades for whom an R2T4 calculation was completed, and funds were returned in error.
Additionally, R2T4 calculations did not have documentation of review."
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned.
No
We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Management agrees with this finding.
See 0100.25
2024-006
8540.13
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementting your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution's written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
"The College has a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, we were unable to observe evidence that the WISP was formally reviewed and approved.
"
N/A
"The WISP was missing the element discussing the secure disposal of customer information. Additionally, there was not am observable formal review or authorization.
"
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
There is a risk the College’s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner.
Yes
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-006
8540.13
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementting your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution's written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
"The College has a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, we were unable to observe evidence that the WISP was formally reviewed and approved.
"
N/A
"The WISP was missing the element discussing the secure disposal of customer information. Additionally, there was not am observable formal review or authorization.
"
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
There is a risk the College’s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner.
Yes
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-007
8515.01
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Per 34 CFR 690.62 states the Pell grant for an academic year is based
upon the payment and disbursement schedule published by the Secretary for each award year.
34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance."
The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, the University did not notify 3 students of required exit counseling. The University also incorrectly disbursed Pell funds for 4 students.
1845
E
During our eligibility testing of 60 students, we noted that the university did not document evidence of review for controls performed by their third party servicer. The University did not document review of award packaging, professional judgment determinations, COD reporting, or verification procedures. We also noted that 3 students were graduates or withdrawals but did not receive notifcation of required exit counseling. Additionally, out of 37 students receiving Pell, 3 were overawarded and 1 was underawarded. 1 student had an incorrect EFC used in their award packaging.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-007
8515.01
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Per 34 CFR 690.62 states the Pell grant for an academic year is based
upon the payment and disbursement schedule published by the Secretary for each award year.
34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance."
The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, the University did not notify 3 students of required exit counseling. The University also incorrectly disbursed Pell funds for 4 students.
1845
E
During our eligibility testing of 60 students, we noted that the university did not document evidence of review for controls performed by their third party servicer. The University did not document review of award packaging, professional judgment determinations, COD reporting, or verification procedures. We also noted that 3 students were graduates or withdrawals but did not receive notifcation of required exit counseling. Additionally, out of 37 students receiving Pell, 3 were overawarded and 1 was underawarded. 1 student had an incorrect EFC used in their award packaging.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-008
8540.17
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Six Title IV checks were observed during testing that were stale more than 240 days.
4333.85
The University had six stale Title IV checks greater than 240 days
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Funds are not returned to the Department of Education in a timely manner
No
We recommend that the University review policies and procedures related to student refund checks to ensure stale checks are returned to the Department of Education.
Management agrees with this finding.
See 0100.25
2024-008
8540.17
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Six Title IV checks were observed during testing that were stale more than 240 days.
4333.85
The University had six stale Title IV checks greater than 240 days
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Funds are not returned to the Department of Education in a timely manner
No
We recommend that the University review policies and procedures related to student refund checks to ensure stale checks are returned to the Department of Education.
Management agrees with this finding.
See 0100.25
2024-009
8565.02
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by an institution participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. An institution must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
The University did not have documentation that Direct Loan Reconciliation prepared by third-party servicer was reviewed.
N/A
During our testing we examined four months of direct loan reconciliations (August, December, March, & May). For all four, the University's third party servicer (Campus Ivy) performed preparation and review of the reconciliation; however, Urshan did not review the work of Campus Ivy or a SOC1 report.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-009
8565.02
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by an institution participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. An institution must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
The University did not have documentation that Direct Loan Reconciliation prepared by third-party servicer was reviewed.
N/A
During our testing we examined four months of direct loan reconciliations (August, December, March, & May). For all four, the University's third party servicer (Campus Ivy) performed preparation and review of the reconciliation; however, Urshan did not review the work of Campus Ivy or a SOC1 report.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-010
8540.15
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Control finding did not result in material questioned costs-therefore we will document as a SD.
N/A - I/C Finding Only
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, we were unable to observe evidence that the University reviewed cash drawdowns prepared by the third party processor.
N/A
During our testing of Credit Balance refunds, CLA observed that the University did not have documentation of formal review. Additionally, during our testing of Cash Management CLA observed two draws that we were unable to verify review occurred.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25
2024-010
8540.15
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Control finding did not result in material questioned costs-therefore we will document as a SD.
N/A - I/C Finding Only
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, we were unable to observe evidence that the University reviewed cash drawdowns prepared by the third party processor.
N/A
During our testing of Credit Balance refunds, CLA observed that the University did not have documentation of formal review. Additionally, during our testing of Cash Management CLA observed two draws that we were unable to verify review occurred.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25