Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.
Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster
(Significant Deficiency)
Grantor(s): Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268
Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans
And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational
Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins
Loan Program, Federal Direct Student Loans
Award Year: 7/2023 – 6/2024
Award #: N/A
Pass-through Number: N/A
Criteria
34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. (Disbursements to or on Behalf of Students)
34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification)
34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds)
34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting)
Condition
Based on our testing, we noted the following:
• For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that
the loan disbursement notification letter sent that would include, in writing (1) the date and
amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of
that loan or loan disbursement and have the loan proceeds returned to the holder of that loan;
and (3) the procedure and time by which the student or parent must notify the institution that he
or she wishes to cancel the loan, was not sent. However, the student did sign a Master Promissory
Note (MPN), in which the student promises to repay the loan they received.
• For 4 students of the 31 sampled to test Verification, we noted that information was verified
incorrectly between the submitted documentation and the student aid application. Additionally,
in one instance the verification worksheet was not maintained.
For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not
returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV
funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately
returned more than was required by the calculation.
• For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were
instances of noncompliance, including:
o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to
NSLDS.
o For 5 students, enrollment status was not reported timely by the University and/or the
Service Provider to NSLDS (within 60-day requirement).
o For 3 students, the enrollment status should have been reported as Leave of Absence
(LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was
not reported timely by the University and/or the Service Provider to NSLDS.
o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student
file and NSLDS Program Level.
o For 1 student, the NSLDS Program Level effective date did not agree to that of the student
file and NSLDS Campus Level.
o For 1 student, the date of graduation per transcript did not agree to the date reported to
NSLDS on the program and campus level.
Cause
The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office.
Effect
The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students.
Questioned Costs
None.
Recommendation
Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements.
Management’s View and Corrective Action Plan
Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.