Audit 351424

Finding 2024-001: Significant Deficiency - Title IV Credit Balances Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 Federal Award Number: P268K242266 Federal Award Year: June 30, 2024 Criteria: Title IV regulations (34 CFR 668.164(h)(1) require that Title IV credit balances on student accounts be paid directly to the student as soon as possible but no later than 14 days after the balance occurred. A student or parent may authorize the Institution to hold the credit balance to be applied to specified other nontuition fees, room and board charges, up to $200 of prior year, or future charges as noted in the regulations at (34 CFR 668.165(b)). Condition/Context: For 7 of 25 students tested, the students’ Title IV credit balances on their accounts were held for longer than the 14-day maximum, without student or parent authorization. The sample was not a statistically valid sample. Cause: The University's controls surrounding Title IV credit balances being paid timely or being held only when authorized by the student/parent did not detect or appropriately handle the Title IV credit balances. Effect: Title IV credit balances were held without student/parent authorization longer than the 14-day maximum. Questioned Costs: Total questioned costs were $27,834 of Federal Direct Student Loan funds (ALN 84.268). Recommendation: The University should revise its procedures to ensure Title IV credit balances are paid timely or student/parent authorizations to hold funds are obtained. Management's Response: The University agrees with the finding. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review is being conducted of current internal control processes and evaluating what additional reporting is capable within the student information system to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances are being monitored during the Spring 2025 terms and new procedures will be put in place for the Fall 2025 term.

Finding 2024-002: Significant Deficiency – Enrollment Reporting Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 Federal Award Number: P268K242266 Federal Award Year: June 30, 2024 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. 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 institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the 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 (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: For 1 of the 28, students who were tested, the incorrect withdrawal effective date was reported to NSLDS. That student's status was also not reported to NSLDS within 60 days. The sample was not a statistically valid sample. Cause: The University's processes did not ensure accurate and timely reporting to NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: Not applicable. Context: Not applicable. Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management's Response: Although enhanced monitoring processes were in place to ensure integrity and punctuality of data reported to the National Student Data Loan System, the University experienced challenges in timely reporting due to staff turnover. The enhanced monitoring and reporting processes have been updated and documented and the University built redundancy into the staffing model to prevent future discrepancies.

Finding 2024-001: Significant Deficiency - Title IV Credit Balances Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 Federal Award Number: P268K242266 Federal Award Year: June 30, 2024 Criteria: Title IV regulations (34 CFR 668.164(h)(1) require that Title IV credit balances on student accounts be paid directly to the student as soon as possible but no later than 14 days after the balance occurred. A student or parent may authorize the Institution to hold the credit balance to be applied to specified other nontuition fees, room and board charges, up to $200 of prior year, or future charges as noted in the regulations at (34 CFR 668.165(b)). Condition/Context: For 7 of 25 students tested, the students’ Title IV credit balances on their accounts were held for longer than the 14-day maximum, without student or parent authorization. The sample was not a statistically valid sample. Cause: The University's controls surrounding Title IV credit balances being paid timely or being held only when authorized by the student/parent did not detect or appropriately handle the Title IV credit balances. Effect: Title IV credit balances were held without student/parent authorization longer than the 14-day maximum. Questioned Costs: Total questioned costs were $27,834 of Federal Direct Student Loan funds (ALN 84.268). Recommendation: The University should revise its procedures to ensure Title IV credit balances are paid timely or student/parent authorizations to hold funds are obtained. Management's Response: The University agrees with the finding. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review is being conducted of current internal control processes and evaluating what additional reporting is capable within the student information system to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances are being monitored during the Spring 2025 terms and new procedures will be put in place for the Fall 2025 term.

Finding 2024-002: Significant Deficiency – Enrollment Reporting Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 Federal Award Number: P268K242266 Federal Award Year: June 30, 2024 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. 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 institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the 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 (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: For 1 of the 28, students who were tested, the incorrect withdrawal effective date was reported to NSLDS. That student's status was also not reported to NSLDS within 60 days. The sample was not a statistically valid sample. Cause: The University's processes did not ensure accurate and timely reporting to NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: Not applicable. Context: Not applicable. Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management's Response: Although enhanced monitoring processes were in place to ensure integrity and punctuality of data reported to the National Student Data Loan System, the University experienced challenges in timely reporting due to staff turnover. The enhanced monitoring and reporting processes have been updated and documented and the University built redundancy into the staffing model to prevent future discrepancies.