Identification of Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition – During our cash management testing, we noted multiple instances during the fiscal year where funds drawn were held in excess of the allowable time frame and/or allowable thresholds.
Cause – Insufficient internal controls and administrative oversight with respect to cash management compliance requirements.
Effect or Potential Effect¬ – The University is not properly following policies and procedures in place to ensure that compliance is maintained with cash management requirements and the timely return of funds.
Questioned Costs – None.
Context – We examined all draws of federal funds and identified multiple instances of cash held in excess of the allowable time frame and/or allowable thresholds as noted in the condition.
Identification of Repeat Finding – This is a repeat finding from prior year. This was reported as Finding 2023-004 in the prior year schedule of findings and questioned costs.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that excess cash balances are eliminated timely.
Views of Responsible Officials – The University concurs with the finding. We have made necessary changes in personnel to mitigate the risk of these actions repeating. We have implemented new controls over cash management and implemented additional internal controls. The University will make disbursements as soon as they are available, but no later than the three (3) business days following receipt of funds. University policies and procedures will be followed closely to ensure there is no excess cash. All funds will be returned in a timely manner.
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition – During our cash management testing, we noted multiple instances during the fiscal year where funds drawn were held in excess of the allowable time frame and/or allowable thresholds.
Cause – Insufficient internal controls and administrative oversight with respect to cash management compliance requirements.
Effect or Potential Effect¬ – The University is not properly following policies and procedures in place to ensure that compliance is maintained with cash management requirements and the timely return of funds.
Questioned Costs – None.
Context – We examined all draws of federal funds and identified multiple instances of cash held in excess of the allowable time frame and/or allowable thresholds as noted in the condition.
Identification of Repeat Finding – This is a repeat finding from prior year. This was reported as Finding 2023-004 in the prior year schedule of findings and questioned costs.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that excess cash balances are eliminated timely.
Views of Responsible Officials – The University concurs with the finding. We have made necessary changes in personnel to mitigate the risk of these actions repeating. We have implemented new controls over cash management and implemented additional internal controls. The University will make disbursements as soon as they are available, but no later than the three (3) business days following receipt of funds. University policies and procedures will be followed closely to ensure there is no excess cash. All funds will be returned in a timely manner.
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition – During our cash management testing, we noted multiple instances during the fiscal year where funds drawn were held in excess of the allowable time frame and/or allowable thresholds.
Cause – Insufficient internal controls and administrative oversight with respect to cash management compliance requirements.
Effect or Potential Effect¬ – The University is not properly following policies and procedures in place to ensure that compliance is maintained with cash management requirements and the timely return of funds.
Questioned Costs – None.
Context – We examined all draws of federal funds and identified multiple instances of cash held in excess of the allowable time frame and/or allowable thresholds as noted in the condition.
Identification of Repeat Finding – This is a repeat finding from prior year. This was reported as Finding 2023-004 in the prior year schedule of findings and questioned costs.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that excess cash balances are eliminated timely.
Views of Responsible Officials – The University concurs with the finding. We have made necessary changes in personnel to mitigate the risk of these actions repeating. We have implemented new controls over cash management and implemented additional internal controls. The University will make disbursements as soon as they are available, but no later than the three (3) business days following receipt of funds. University policies and procedures will be followed closely to ensure there is no excess cash. All funds will be returned in a timely manner.
Identification of Federal Program(s) – Federal Supplemental Educational Opportunity Grants (ALN 84.007)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – The Federal Supplemental Educational Opportunity Grant (“FSEOG”) program provides grants to eligible undergraduate students. Priority is given to Federal Pell Grant recipients who have the lowest expected family contributions (34 CFR 676.10).
Condition – During our eligibility testing, we noted that priority was not given to Pell recipients when disbursing FSEOG awards.
Cause – Insufficient internal controls and administrative oversight with respect to giving priority to Pell recipients when disbursing FSEOG Awards.
Effect or Potential Effect¬ – The University did not give priority to Federal Pell Grant (“Pell”) recipients with the lowest expected family contributions when disbursing FSEOG awards.
Questioned Costs – Below reporting threshold.
Context – We examined the University’s awards disbursement detail noting that all Pell recipients did not receive FSEOG awards. In addition, we identified 5 FSEOG recipients who were not Pell recipients.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure priority is given to Pell recipients when disbursing FSEOG awards.
Views of Responsible Officials – The University concurs with the finding. In selecting among eligible students for FSEOG in each award year, the office of Financial Aid will select first those students with the lowest expected family contribution and the highest need who also received Federal Pell Grants in that year. Management will implement and document an internal audit review. A monthly reconciliation will be completed to ensure Pell recipients are awarded FSEOG, based on the guidance provided by the Federal handbook
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by October 1, following the end of the award year, and to accurately complete all required key line items containing critical information (34 CFR 668.24(e)(1)(i)). The deadline for submitting data corrections was December 13, 2024.
Condition – Key line items as identified in the compliance supplement were not accurately reported on the 2023-2024 FISAP.
Cause – Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP.
Effect or Potential Effect¬ – The University is not in compliance with special reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, errors included in the submission were not corrected by the required deadline. As of the date of our Single Audit report, these errors remain uncorrected.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend the University enhance its internal controls, policies, and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials – The University concurs with the finding. The University will make any necessary changes and corrections to ensure that the FISAP is submitted annually by October 1 following the end of the award year. This ensures that all data corrections are submitted on or before the deadline. The Financial aid Office will implement a process to enhance internal controls, policies and procedures, to ensure the FISAP is submitted accurately and timely
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by October 1, following the end of the award year, and to accurately complete all required key line items containing critical information (34 CFR 668.24(e)(1)(i)). The deadline for submitting data corrections was December 13, 2024.
Condition – Key line items as identified in the compliance supplement were not accurately reported on the 2023-2024 FISAP.
Cause – Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP.
Effect or Potential Effect¬ – The University is not in compliance with special reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, errors included in the submission were not corrected by the required deadline. As of the date of our Single Audit report, these errors remain uncorrected.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend the University enhance its internal controls, policies, and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials – The University concurs with the finding. The University will make any necessary changes and corrections to ensure that the FISAP is submitted annually by October 1 following the end of the award year. This ensures that all data corrections are submitted on or before the deadline. The Financial aid Office will implement a process to enhance internal controls, policies and procedures, to ensure the FISAP is submitted accurately and timely
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by October 1, following the end of the award year, and to accurately complete all required key line items containing critical information (34 CFR 668.24(e)(1)(i)). The deadline for submitting data corrections was December 13, 2024.
Condition – Key line items as identified in the compliance supplement were not accurately reported on the 2023-2024 FISAP.
Cause – Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP.
Effect or Potential Effect¬ – The University is not in compliance with special reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, errors included in the submission were not corrected by the required deadline. As of the date of our Single Audit report, these errors remain uncorrected.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend the University enhance its internal controls, policies, and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials – The University concurs with the finding. The University will make any necessary changes and corrections to ensure that the FISAP is submitted annually by October 1 following the end of the award year. This ensures that all data corrections are submitted on or before the deadline. The Financial aid Office will implement a process to enhance internal controls, policies and procedures, to ensure the FISAP is submitted accurately and timely
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by October 1, following the end of the award year, and to accurately complete all required key line items containing critical information (34 CFR 668.24(e)(1)(i)). The deadline for submitting data corrections was December 13, 2024.
Condition – Key line items as identified in the compliance supplement were not accurately reported on the 2023-2024 FISAP.
Cause – Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP.
Effect or Potential Effect¬ – The University is not in compliance with special reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, errors included in the submission were not corrected by the required deadline. As of the date of our Single Audit report, these errors remain uncorrected.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend the University enhance its internal controls, policies, and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials – The University concurs with the finding. The University will make any necessary changes and corrections to ensure that the FISAP is submitted annually by October 1 following the end of the award year. This ensures that all data corrections are submitted on or before the deadline. The Financial aid Office will implement a process to enhance internal controls, policies and procedures, to ensure the FISAP is submitted accurately and timely
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Return of Title IV Funds - The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education (“ED”) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR section 668.173(b)). If a student does not begin attendance in a payment period or period of enrollment, the institution must return all Title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for that payment period or period of enrollment. The institution must return those funds for which it is responsible under to the respective Title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR section 668.21). If the total amount of Title IV grant or loan assistance, or both, that the student earned is greater than the total amount of Title IV grant or loan assistance, or both, that was disbursed to the student of on behalf of the student in the case of a PLUS loan, as of the date of the institution’s determination that the student withdrew, the difference between these amounts must be treated as a post-withdrawal disbursement. If outstanding charges exist on the student’s account, the institution may credit the student’s account up to the amount of outstanding charges with all or any portion of loan funds that make up the post-withdrawal disbursement in accordance with 34 CFR sections 668.164(d)(1), (d)(2), and (d)(3) only after obtaining confirmation from the student or parent in the case of a PLUS loan, that they still wish to have the loan funds disbursed to their account (34 CFR sections 668.22(a)(5) and (a)(6)(ii)(A)).
Condition – Refund calculation for a certain student selected for testing was appropriately prepared however, the University did not return funds to the ED within the required time frame for certain students selected for testing.
Cause – Insufficient internal controls and lack of administrative oversight over the return of Title IV funds.
Effect or Potential Effect¬ – The University is not in compliance with the required federal guidelines over the return of Title IV funds.
Questioned Costs – Below reporting threshold.
Context – For 1 of 3 students selected for testing, Title IV funds required to be returned were not submitted to the ED within the required time frame.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that Title IV funds are returned within the required timeframe.
Views of Responsible Officials – The University concurs with the finding and will monitor internal controls to ensure that the return of Title IV funds is processed in accordance with federal regulations, specifically within the required 45-day timeframe after determining a student has withdrawn from the University. The University will establish a quarterly audit and monitoring system to review all Title IV fund returns, ensuring compliance with federal guidelines.
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Return of Title IV Funds - The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education (“ED”) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR section 668.173(b)). If a student does not begin attendance in a payment period or period of enrollment, the institution must return all Title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for that payment period or period of enrollment. The institution must return those funds for which it is responsible under to the respective Title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR section 668.21). If the total amount of Title IV grant or loan assistance, or both, that the student earned is greater than the total amount of Title IV grant or loan assistance, or both, that was disbursed to the student of on behalf of the student in the case of a PLUS loan, as of the date of the institution’s determination that the student withdrew, the difference between these amounts must be treated as a post-withdrawal disbursement. If outstanding charges exist on the student’s account, the institution may credit the student’s account up to the amount of outstanding charges with all or any portion of loan funds that make up the post-withdrawal disbursement in accordance with 34 CFR sections 668.164(d)(1), (d)(2), and (d)(3) only after obtaining confirmation from the student or parent in the case of a PLUS loan, that they still wish to have the loan funds disbursed to their account (34 CFR sections 668.22(a)(5) and (a)(6)(ii)(A)).
Condition – Refund calculation for a certain student selected for testing was appropriately prepared however, the University did not return funds to the ED within the required time frame for certain students selected for testing.
Cause – Insufficient internal controls and lack of administrative oversight over the return of Title IV funds.
Effect or Potential Effect¬ – The University is not in compliance with the required federal guidelines over the return of Title IV funds.
Questioned Costs – Below reporting threshold.
Context – For 1 of 3 students selected for testing, Title IV funds required to be returned were not submitted to the ED within the required time frame.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that Title IV funds are returned within the required timeframe.
Views of Responsible Officials – The University concurs with the finding and will monitor internal controls to ensure that the return of Title IV funds is processed in accordance with federal regulations, specifically within the required 45-day timeframe after determining a student has withdrawn from the University. The University will establish a quarterly audit and monitoring system to review all Title IV fund returns, ensuring compliance with federal guidelines.
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Return of Title IV Funds - The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education (“ED”) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR section 668.173(b)). If a student does not begin attendance in a payment period or period of enrollment, the institution must return all Title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for that payment period or period of enrollment. The institution must return those funds for which it is responsible under to the respective Title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR section 668.21). If the total amount of Title IV grant or loan assistance, or both, that the student earned is greater than the total amount of Title IV grant or loan assistance, or both, that was disbursed to the student of on behalf of the student in the case of a PLUS loan, as of the date of the institution’s determination that the student withdrew, the difference between these amounts must be treated as a post-withdrawal disbursement. If outstanding charges exist on the student’s account, the institution may credit the student’s account up to the amount of outstanding charges with all or any portion of loan funds that make up the post-withdrawal disbursement in accordance with 34 CFR sections 668.164(d)(1), (d)(2), and (d)(3) only after obtaining confirmation from the student or parent in the case of a PLUS loan, that they still wish to have the loan funds disbursed to their account (34 CFR sections 668.22(a)(5) and (a)(6)(ii)(A)).
Condition – Refund calculation for a certain student selected for testing was appropriately prepared however, the University did not return funds to the ED within the required time frame for certain students selected for testing.
Cause – Insufficient internal controls and lack of administrative oversight over the return of Title IV funds.
Effect or Potential Effect¬ – The University is not in compliance with the required federal guidelines over the return of Title IV funds.
Questioned Costs – Below reporting threshold.
Context – For 1 of 3 students selected for testing, Title IV funds required to be returned were not submitted to the ED within the required time frame.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that Title IV funds are returned within the required timeframe.
Views of Responsible Officials – The University concurs with the finding and will monitor internal controls to ensure that the return of Title IV funds is processed in accordance with federal regulations, specifically within the required 45-day timeframe after determining a student has withdrawn from the University. The University will establish a quarterly audit and monitoring system to review all Title IV fund returns, ensuring compliance with federal guidelines.
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Enrollment Reporting – The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” each with separate record types that need to be reported accurately. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely (34 CFR 685.309(b), 685.210(c), and 690.83(b)(2)).
Condition – For certain students selected for testing who graduated or withdrew during the year, the University did not submit status change notification or failed to submit timely notification to the NSLDS website.
Cause – Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect¬ – The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – The University did not accurately report Campus Level enrollment data elements to the NSLDS website for 1 of 25 Federal Pell Grant and Federal Direct Student Loan recipients selected for testing that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the fiscal year.
The University did not accurately report Program Level enrollment data elements to the NSLDS website for 6 of 25 Federal Pell Grant and Federal Direct Student Loan recipients selected for testing that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, our enrolled but never attended during the fiscal year.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures over the applicable compliance requirements of the Enrollment Reporting to ensure that all Campus Level and Program Level data is reported accurately and status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University concurs with the finding and will review and revise its procedures for the frequency of NSLDS reporting to ensure accurate and timely reporting of enrollment changes. The University will implement a monthly enrollment audit to ensure that any change in enrollment status is identified in a timely manner and reported to NSLDS
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Enrollment Reporting – The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” each with separate record types that need to be reported accurately. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely (34 CFR 685.309(b), 685.210(c), and 690.83(b)(2)).
Condition – For certain students selected for testing who graduated or withdrew during the year, the University did not submit status change notification or failed to submit timely notification to the NSLDS website.
Cause – Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect¬ – The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – The University did not accurately report Campus Level enrollment data elements to the NSLDS website for 1 of 25 Federal Pell Grant and Federal Direct Student Loan recipients selected for testing that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the fiscal year.
The University did not accurately report Program Level enrollment data elements to the NSLDS website for 6 of 25 Federal Pell Grant and Federal Direct Student Loan recipients selected for testing that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, our enrolled but never attended during the fiscal year.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures over the applicable compliance requirements of the Enrollment Reporting to ensure that all Campus Level and Program Level data is reported accurately and status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University concurs with the finding and will review and revise its procedures for the frequency of NSLDS reporting to ensure accurate and timely reporting of enrollment changes. The University will implement a monthly enrollment audit to ensure that any change in enrollment status is identified in a timely manner and reported to NSLDS
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition – During our cash management testing, we noted multiple instances during the fiscal year where funds drawn were held in excess of the allowable time frame and/or allowable thresholds.
Cause – Insufficient internal controls and administrative oversight with respect to cash management compliance requirements.
Effect or Potential Effect¬ – The University is not properly following policies and procedures in place to ensure that compliance is maintained with cash management requirements and the timely return of funds.
Questioned Costs – None.
Context – We examined all draws of federal funds and identified multiple instances of cash held in excess of the allowable time frame and/or allowable thresholds as noted in the condition.
Identification of Repeat Finding – This is a repeat finding from prior year. This was reported as Finding 2023-004 in the prior year schedule of findings and questioned costs.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that excess cash balances are eliminated timely.
Views of Responsible Officials – The University concurs with the finding. We have made necessary changes in personnel to mitigate the risk of these actions repeating. We have implemented new controls over cash management and implemented additional internal controls. The University will make disbursements as soon as they are available, but no later than the three (3) business days following receipt of funds. University policies and procedures will be followed closely to ensure there is no excess cash. All funds will be returned in a timely manner.
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition – During our cash management testing, we noted multiple instances during the fiscal year where funds drawn were held in excess of the allowable time frame and/or allowable thresholds.
Cause – Insufficient internal controls and administrative oversight with respect to cash management compliance requirements.
Effect or Potential Effect¬ – The University is not properly following policies and procedures in place to ensure that compliance is maintained with cash management requirements and the timely return of funds.
Questioned Costs – None.
Context – We examined all draws of federal funds and identified multiple instances of cash held in excess of the allowable time frame and/or allowable thresholds as noted in the condition.
Identification of Repeat Finding – This is a repeat finding from prior year. This was reported as Finding 2023-004 in the prior year schedule of findings and questioned costs.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that excess cash balances are eliminated timely.
Views of Responsible Officials – The University concurs with the finding. We have made necessary changes in personnel to mitigate the risk of these actions repeating. We have implemented new controls over cash management and implemented additional internal controls. The University will make disbursements as soon as they are available, but no later than the three (3) business days following receipt of funds. University policies and procedures will be followed closely to ensure there is no excess cash. All funds will be returned in a timely manner.
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition – During our cash management testing, we noted multiple instances during the fiscal year where funds drawn were held in excess of the allowable time frame and/or allowable thresholds.
Cause – Insufficient internal controls and administrative oversight with respect to cash management compliance requirements.
Effect or Potential Effect¬ – The University is not properly following policies and procedures in place to ensure that compliance is maintained with cash management requirements and the timely return of funds.
Questioned Costs – None.
Context – We examined all draws of federal funds and identified multiple instances of cash held in excess of the allowable time frame and/or allowable thresholds as noted in the condition.
Identification of Repeat Finding – This is a repeat finding from prior year. This was reported as Finding 2023-004 in the prior year schedule of findings and questioned costs.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that excess cash balances are eliminated timely.
Views of Responsible Officials – The University concurs with the finding. We have made necessary changes in personnel to mitigate the risk of these actions repeating. We have implemented new controls over cash management and implemented additional internal controls. The University will make disbursements as soon as they are available, but no later than the three (3) business days following receipt of funds. University policies and procedures will be followed closely to ensure there is no excess cash. All funds will be returned in a timely manner.
Identification of Federal Program(s) – Federal Supplemental Educational Opportunity Grants (ALN 84.007)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – The Federal Supplemental Educational Opportunity Grant (“FSEOG”) program provides grants to eligible undergraduate students. Priority is given to Federal Pell Grant recipients who have the lowest expected family contributions (34 CFR 676.10).
Condition – During our eligibility testing, we noted that priority was not given to Pell recipients when disbursing FSEOG awards.
Cause – Insufficient internal controls and administrative oversight with respect to giving priority to Pell recipients when disbursing FSEOG Awards.
Effect or Potential Effect¬ – The University did not give priority to Federal Pell Grant (“Pell”) recipients with the lowest expected family contributions when disbursing FSEOG awards.
Questioned Costs – Below reporting threshold.
Context – We examined the University’s awards disbursement detail noting that all Pell recipients did not receive FSEOG awards. In addition, we identified 5 FSEOG recipients who were not Pell recipients.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure priority is given to Pell recipients when disbursing FSEOG awards.
Views of Responsible Officials – The University concurs with the finding. In selecting among eligible students for FSEOG in each award year, the office of Financial Aid will select first those students with the lowest expected family contribution and the highest need who also received Federal Pell Grants in that year. Management will implement and document an internal audit review. A monthly reconciliation will be completed to ensure Pell recipients are awarded FSEOG, based on the guidance provided by the Federal handbook
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by October 1, following the end of the award year, and to accurately complete all required key line items containing critical information (34 CFR 668.24(e)(1)(i)). The deadline for submitting data corrections was December 13, 2024.
Condition – Key line items as identified in the compliance supplement were not accurately reported on the 2023-2024 FISAP.
Cause – Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP.
Effect or Potential Effect¬ – The University is not in compliance with special reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, errors included in the submission were not corrected by the required deadline. As of the date of our Single Audit report, these errors remain uncorrected.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend the University enhance its internal controls, policies, and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials – The University concurs with the finding. The University will make any necessary changes and corrections to ensure that the FISAP is submitted annually by October 1 following the end of the award year. This ensures that all data corrections are submitted on or before the deadline. The Financial aid Office will implement a process to enhance internal controls, policies and procedures, to ensure the FISAP is submitted accurately and timely
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by October 1, following the end of the award year, and to accurately complete all required key line items containing critical information (34 CFR 668.24(e)(1)(i)). The deadline for submitting data corrections was December 13, 2024.
Condition – Key line items as identified in the compliance supplement were not accurately reported on the 2023-2024 FISAP.
Cause – Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP.
Effect or Potential Effect¬ – The University is not in compliance with special reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, errors included in the submission were not corrected by the required deadline. As of the date of our Single Audit report, these errors remain uncorrected.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend the University enhance its internal controls, policies, and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials – The University concurs with the finding. The University will make any necessary changes and corrections to ensure that the FISAP is submitted annually by October 1 following the end of the award year. This ensures that all data corrections are submitted on or before the deadline. The Financial aid Office will implement a process to enhance internal controls, policies and procedures, to ensure the FISAP is submitted accurately and timely
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by October 1, following the end of the award year, and to accurately complete all required key line items containing critical information (34 CFR 668.24(e)(1)(i)). The deadline for submitting data corrections was December 13, 2024.
Condition – Key line items as identified in the compliance supplement were not accurately reported on the 2023-2024 FISAP.
Cause – Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP.
Effect or Potential Effect¬ – The University is not in compliance with special reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, errors included in the submission were not corrected by the required deadline. As of the date of our Single Audit report, these errors remain uncorrected.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend the University enhance its internal controls, policies, and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials – The University concurs with the finding. The University will make any necessary changes and corrections to ensure that the FISAP is submitted annually by October 1 following the end of the award year. This ensures that all data corrections are submitted on or before the deadline. The Financial aid Office will implement a process to enhance internal controls, policies and procedures, to ensure the FISAP is submitted accurately and timely
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by October 1, following the end of the award year, and to accurately complete all required key line items containing critical information (34 CFR 668.24(e)(1)(i)). The deadline for submitting data corrections was December 13, 2024.
Condition – Key line items as identified in the compliance supplement were not accurately reported on the 2023-2024 FISAP.
Cause – Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP.
Effect or Potential Effect¬ – The University is not in compliance with special reporting requirements.
Questioned Costs – None.
Context – The University submitted the annual FISAP for the 2023-2024 reporting year by the required deadline; however, errors included in the submission were not corrected by the required deadline. As of the date of our Single Audit report, these errors remain uncorrected.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend the University enhance its internal controls, policies, and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials – The University concurs with the finding. The University will make any necessary changes and corrections to ensure that the FISAP is submitted annually by October 1 following the end of the award year. This ensures that all data corrections are submitted on or before the deadline. The Financial aid Office will implement a process to enhance internal controls, policies and procedures, to ensure the FISAP is submitted accurately and timely
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Return of Title IV Funds - The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education (“ED”) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR section 668.173(b)). If a student does not begin attendance in a payment period or period of enrollment, the institution must return all Title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for that payment period or period of enrollment. The institution must return those funds for which it is responsible under to the respective Title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR section 668.21). If the total amount of Title IV grant or loan assistance, or both, that the student earned is greater than the total amount of Title IV grant or loan assistance, or both, that was disbursed to the student of on behalf of the student in the case of a PLUS loan, as of the date of the institution’s determination that the student withdrew, the difference between these amounts must be treated as a post-withdrawal disbursement. If outstanding charges exist on the student’s account, the institution may credit the student’s account up to the amount of outstanding charges with all or any portion of loan funds that make up the post-withdrawal disbursement in accordance with 34 CFR sections 668.164(d)(1), (d)(2), and (d)(3) only after obtaining confirmation from the student or parent in the case of a PLUS loan, that they still wish to have the loan funds disbursed to their account (34 CFR sections 668.22(a)(5) and (a)(6)(ii)(A)).
Condition – Refund calculation for a certain student selected for testing was appropriately prepared however, the University did not return funds to the ED within the required time frame for certain students selected for testing.
Cause – Insufficient internal controls and lack of administrative oversight over the return of Title IV funds.
Effect or Potential Effect¬ – The University is not in compliance with the required federal guidelines over the return of Title IV funds.
Questioned Costs – Below reporting threshold.
Context – For 1 of 3 students selected for testing, Title IV funds required to be returned were not submitted to the ED within the required time frame.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that Title IV funds are returned within the required timeframe.
Views of Responsible Officials – The University concurs with the finding and will monitor internal controls to ensure that the return of Title IV funds is processed in accordance with federal regulations, specifically within the required 45-day timeframe after determining a student has withdrawn from the University. The University will establish a quarterly audit and monitoring system to review all Title IV fund returns, ensuring compliance with federal guidelines.
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Return of Title IV Funds - The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education (“ED”) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR section 668.173(b)). If a student does not begin attendance in a payment period or period of enrollment, the institution must return all Title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for that payment period or period of enrollment. The institution must return those funds for which it is responsible under to the respective Title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR section 668.21). If the total amount of Title IV grant or loan assistance, or both, that the student earned is greater than the total amount of Title IV grant or loan assistance, or both, that was disbursed to the student of on behalf of the student in the case of a PLUS loan, as of the date of the institution’s determination that the student withdrew, the difference between these amounts must be treated as a post-withdrawal disbursement. If outstanding charges exist on the student’s account, the institution may credit the student’s account up to the amount of outstanding charges with all or any portion of loan funds that make up the post-withdrawal disbursement in accordance with 34 CFR sections 668.164(d)(1), (d)(2), and (d)(3) only after obtaining confirmation from the student or parent in the case of a PLUS loan, that they still wish to have the loan funds disbursed to their account (34 CFR sections 668.22(a)(5) and (a)(6)(ii)(A)).
Condition – Refund calculation for a certain student selected for testing was appropriately prepared however, the University did not return funds to the ED within the required time frame for certain students selected for testing.
Cause – Insufficient internal controls and lack of administrative oversight over the return of Title IV funds.
Effect or Potential Effect¬ – The University is not in compliance with the required federal guidelines over the return of Title IV funds.
Questioned Costs – Below reporting threshold.
Context – For 1 of 3 students selected for testing, Title IV funds required to be returned were not submitted to the ED within the required time frame.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that Title IV funds are returned within the required timeframe.
Views of Responsible Officials – The University concurs with the finding and will monitor internal controls to ensure that the return of Title IV funds is processed in accordance with federal regulations, specifically within the required 45-day timeframe after determining a student has withdrawn from the University. The University will establish a quarterly audit and monitoring system to review all Title IV fund returns, ensuring compliance with federal guidelines.
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Return of Title IV Funds - The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education (“ED”) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR section 668.173(b)). If a student does not begin attendance in a payment period or period of enrollment, the institution must return all Title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for that payment period or period of enrollment. The institution must return those funds for which it is responsible under to the respective Title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR section 668.21). If the total amount of Title IV grant or loan assistance, or both, that the student earned is greater than the total amount of Title IV grant or loan assistance, or both, that was disbursed to the student of on behalf of the student in the case of a PLUS loan, as of the date of the institution’s determination that the student withdrew, the difference between these amounts must be treated as a post-withdrawal disbursement. If outstanding charges exist on the student’s account, the institution may credit the student’s account up to the amount of outstanding charges with all or any portion of loan funds that make up the post-withdrawal disbursement in accordance with 34 CFR sections 668.164(d)(1), (d)(2), and (d)(3) only after obtaining confirmation from the student or parent in the case of a PLUS loan, that they still wish to have the loan funds disbursed to their account (34 CFR sections 668.22(a)(5) and (a)(6)(ii)(A)).
Condition – Refund calculation for a certain student selected for testing was appropriately prepared however, the University did not return funds to the ED within the required time frame for certain students selected for testing.
Cause – Insufficient internal controls and lack of administrative oversight over the return of Title IV funds.
Effect or Potential Effect¬ – The University is not in compliance with the required federal guidelines over the return of Title IV funds.
Questioned Costs – Below reporting threshold.
Context – For 1 of 3 students selected for testing, Title IV funds required to be returned were not submitted to the ED within the required time frame.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that Title IV funds are returned within the required timeframe.
Views of Responsible Officials – The University concurs with the finding and will monitor internal controls to ensure that the return of Title IV funds is processed in accordance with federal regulations, specifically within the required 45-day timeframe after determining a student has withdrawn from the University. The University will establish a quarterly audit and monitoring system to review all Title IV fund returns, ensuring compliance with federal guidelines.
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Enrollment Reporting – The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” each with separate record types that need to be reported accurately. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely (34 CFR 685.309(b), 685.210(c), and 690.83(b)(2)).
Condition – For certain students selected for testing who graduated or withdrew during the year, the University did not submit status change notification or failed to submit timely notification to the NSLDS website.
Cause – Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect¬ – The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – The University did not accurately report Campus Level enrollment data elements to the NSLDS website for 1 of 25 Federal Pell Grant and Federal Direct Student Loan recipients selected for testing that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the fiscal year.
The University did not accurately report Program Level enrollment data elements to the NSLDS website for 6 of 25 Federal Pell Grant and Federal Direct Student Loan recipients selected for testing that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, our enrolled but never attended during the fiscal year.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures over the applicable compliance requirements of the Enrollment Reporting to ensure that all Campus Level and Program Level data is reported accurately and status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University concurs with the finding and will review and revise its procedures for the frequency of NSLDS reporting to ensure accurate and timely reporting of enrollment changes. The University will implement a monthly enrollment audit to ensure that any change in enrollment status is identified in a timely manner and reported to NSLDS
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Enrollment Reporting – The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” each with separate record types that need to be reported accurately. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely (34 CFR 685.309(b), 685.210(c), and 690.83(b)(2)).
Condition – For certain students selected for testing who graduated or withdrew during the year, the University did not submit status change notification or failed to submit timely notification to the NSLDS website.
Cause – Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect¬ – The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – The University did not accurately report Campus Level enrollment data elements to the NSLDS website for 1 of 25 Federal Pell Grant and Federal Direct Student Loan recipients selected for testing that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the fiscal year.
The University did not accurately report Program Level enrollment data elements to the NSLDS website for 6 of 25 Federal Pell Grant and Federal Direct Student Loan recipients selected for testing that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, our enrolled but never attended during the fiscal year.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures over the applicable compliance requirements of the Enrollment Reporting to ensure that all Campus Level and Program Level data is reported accurately and status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University concurs with the finding and will review and revise its procedures for the frequency of NSLDS reporting to ensure accurate and timely reporting of enrollment changes. The University will implement a monthly enrollment audit to ensure that any change in enrollment status is identified in a timely manner and reported to NSLDS