FINDING 2024-003
Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. Additionally, 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to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn (34 CFR section 668.173(b)).
Condition: The University did not appropriately return the amount of unearned funds within the required timeframe.
Cause: The University correctly determined the amount of Title IV aid earned for a student, but due to administrative oversight, erroneously processed the return of funds.
Effect or Potential Effect: Returns of Title IV funds were not made within the required timeframe.
Questioned Costs: None.
Context: For 1 of 6 students tested, the amount calculated as due for return was not appropriately returned.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures over return of Title IV funds to ensure unearned portions of federal aid are appropriately returned to the U.S. Department of Education.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The University correctly determined the
amount of Title IV aid earned for a student within the required timeframes, but due to administrative oversight, omitted one of the required awards from the return update on the student account. A regular review of R2T4 calculations will be developed to ensure that the actual returns match the return calculations.
FINDING 2024-001
Federal Program Information: Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) Loan Program via the National Student Loan Data System (the “NSLDS”) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Condition: Certain students’ campus-level enrollment data was not accurately reported.
Cause: In both instances, the graduate submission schedules were reported to the registrar timely. Subsequent to that date, both students were qualified to graduate, however, updated student statuses were not reported to the NSLDS.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 2 of 40 campus level records tested, the students’ enrollment statuses were incorrectly reported as withdrawn instead of graduated.
Identification as a Repeat Finding: There was no similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure that campus level enrollment data is timely and accurately reported to NSLDS.
Views of Responsible Officials:
Certain students’ campus level enrollment data was not accurately reported. The Registrar’s Office will determine why certain students falling outside of normal graduate submission schedules are not being captured in DegreeVerify files submitted to the National Student Clearinghouse. Manual submissions for these non-standard graduates will be performed until a reporting solution is identified.
FINDING 2024-003
Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. Additionally, 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 U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn (34 CFR section 668.173(b)).
Condition: The University did not appropriately return the amount of unearned funds within the required timeframe.
Cause: The University correctly determined the amount of Title IV aid earned for a student, but due to administrative oversight, erroneously processed the return of funds.
Effect or Potential Effect: Returns of Title IV funds were not made within the required timeframe.
Questioned Costs: None.
Context: For 1 of 6 students tested, the amount calculated as due for return was not appropriately returned.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures over return of Title IV funds to ensure unearned portions of federal aid are appropriately returned to the U.S. Department of Education.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The University correctly determined the
amount of Title IV aid earned for a student within the required timeframes, but due to administrative oversight, omitted one of the required awards from the return update on the student account. A regular review of R2T4 calculations will be developed to ensure that the actual returns match the return calculations.
FINDING 2024-001
Federal Program Information: Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) Loan Program via the National Student Loan Data System (the “NSLDS”) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Condition: Certain students’ campus-level enrollment data was not accurately reported.
Cause: In both instances, the graduate submission schedules were reported to the registrar timely. Subsequent to that date, both students were qualified to graduate, however, updated student statuses were not reported to the NSLDS.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 2 of 40 campus level records tested, the students’ enrollment statuses were incorrectly reported as withdrawn instead of graduated.
Identification as a Repeat Finding: There was no similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure that campus level enrollment data is timely and accurately reported to NSLDS.
Views of Responsible Officials:
Certain students’ campus level enrollment data was not accurately reported. The Registrar’s Office will determine why certain students falling outside of normal graduate submission schedules are not being captured in DegreeVerify files submitted to the National Student Clearinghouse. Manual submissions for these non-standard graduates will be performed until a reporting solution is identified.
FINDING 2024-002
Federal Program Information: Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements To or On Behalf of Students - Loan Disbursement Notifications: Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (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 or the TEACH Grant payments returned to the U.S. Department of Education; 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, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition: The University was unable to provide evidence of loan disbursement notifications for certain students.
Cause: Administrative oversight.
Effect or Potential Effect: The University was unable to evidence compliance with loan notification requirements for those students.
Questioned Costs: None.
Context: For 8 of 25 disbursements tested, the University was unable to provide documentation showing that a notification was sent within the required timeframe to the borrower regarding the loan disbursement.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-002.
Recommendation: We recommend the University enhance its procedures over loan notifications to ensure timely and accurate notification to borrowers within the prescribed timeframe.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A loan disbursement notification was sent to the students in question; however, we can only document the loan disbursement notification was sent but are unable to document the date or content of the communication. Students identified with missing communications are from spring 2024. Our internal processes dictate that the notification would normally be sent on the date of disbursement. We will develop and implement a loan disbursement notification to loan recipient reconciliation process to effectively capture students with missing communications to ensure that both a record of the notification and the date are maintained.
FINDING 2024-003
Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. Additionally, 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 U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn (34 CFR section 668.173(b)).
Condition: The University did not appropriately return the amount of unearned funds within the required timeframe.
Cause: The University correctly determined the amount of Title IV aid earned for a student, but due to administrative oversight, erroneously processed the return of funds.
Effect or Potential Effect: Returns of Title IV funds were not made within the required timeframe.
Questioned Costs: None.
Context: For 1 of 6 students tested, the amount calculated as due for return was not appropriately returned.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures over return of Title IV funds to ensure unearned portions of federal aid are appropriately returned to the U.S. Department of Education.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The University correctly determined the
amount of Title IV aid earned for a student within the required timeframes, but due to administrative oversight, omitted one of the required awards from the return update on the student account. A regular review of R2T4 calculations will be developed to ensure that the actual returns match the return calculations.
FINDING 2024-003
Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. Additionally, 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 U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn (34 CFR section 668.173(b)).
Condition: The University did not appropriately return the amount of unearned funds within the required timeframe.
Cause: The University correctly determined the amount of Title IV aid earned for a student, but due to administrative oversight, erroneously processed the return of funds.
Effect or Potential Effect: Returns of Title IV funds were not made within the required timeframe.
Questioned Costs: None.
Context: For 1 of 6 students tested, the amount calculated as due for return was not appropriately returned.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures over return of Title IV funds to ensure unearned portions of federal aid are appropriately returned to the U.S. Department of Education.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The University correctly determined the
amount of Title IV aid earned for a student within the required timeframes, but due to administrative oversight, omitted one of the required awards from the return update on the student account. A regular review of R2T4 calculations will be developed to ensure that the actual returns match the return calculations.
FINDING 2024-001
Federal Program Information: Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) Loan Program via the National Student Loan Data System (the “NSLDS”) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Condition: Certain students’ campus-level enrollment data was not accurately reported.
Cause: In both instances, the graduate submission schedules were reported to the registrar timely. Subsequent to that date, both students were qualified to graduate, however, updated student statuses were not reported to the NSLDS.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 2 of 40 campus level records tested, the students’ enrollment statuses were incorrectly reported as withdrawn instead of graduated.
Identification as a Repeat Finding: There was no similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure that campus level enrollment data is timely and accurately reported to NSLDS.
Views of Responsible Officials:
Certain students’ campus level enrollment data was not accurately reported. The Registrar’s Office will determine why certain students falling outside of normal graduate submission schedules are not being captured in DegreeVerify files submitted to the National Student Clearinghouse. Manual submissions for these non-standard graduates will be performed until a reporting solution is identified.
FINDING 2024-003
Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. Additionally, 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 U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn (34 CFR section 668.173(b)).
Condition: The University did not appropriately return the amount of unearned funds within the required timeframe.
Cause: The University correctly determined the amount of Title IV aid earned for a student, but due to administrative oversight, erroneously processed the return of funds.
Effect or Potential Effect: Returns of Title IV funds were not made within the required timeframe.
Questioned Costs: None.
Context: For 1 of 6 students tested, the amount calculated as due for return was not appropriately returned.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures over return of Title IV funds to ensure unearned portions of federal aid are appropriately returned to the U.S. Department of Education.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The University correctly determined the
amount of Title IV aid earned for a student within the required timeframes, but due to administrative oversight, omitted one of the required awards from the return update on the student account. A regular review of R2T4 calculations will be developed to ensure that the actual returns match the return calculations.
FINDING 2024-001
Federal Program Information: Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) Loan Program via the National Student Loan Data System (the “NSLDS”) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Condition: Certain students’ campus-level enrollment data was not accurately reported.
Cause: In both instances, the graduate submission schedules were reported to the registrar timely. Subsequent to that date, both students were qualified to graduate, however, updated student statuses were not reported to the NSLDS.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 2 of 40 campus level records tested, the students’ enrollment statuses were incorrectly reported as withdrawn instead of graduated.
Identification as a Repeat Finding: There was no similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure that campus level enrollment data is timely and accurately reported to NSLDS.
Views of Responsible Officials:
Certain students’ campus level enrollment data was not accurately reported. The Registrar’s Office will determine why certain students falling outside of normal graduate submission schedules are not being captured in DegreeVerify files submitted to the National Student Clearinghouse. Manual submissions for these non-standard graduates will be performed until a reporting solution is identified.
FINDING 2024-002
Federal Program Information: Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements To or On Behalf of Students - Loan Disbursement Notifications: Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (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 or the TEACH Grant payments returned to the U.S. Department of Education; 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, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition: The University was unable to provide evidence of loan disbursement notifications for certain students.
Cause: Administrative oversight.
Effect or Potential Effect: The University was unable to evidence compliance with loan notification requirements for those students.
Questioned Costs: None.
Context: For 8 of 25 disbursements tested, the University was unable to provide documentation showing that a notification was sent within the required timeframe to the borrower regarding the loan disbursement.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-002.
Recommendation: We recommend the University enhance its procedures over loan notifications to ensure timely and accurate notification to borrowers within the prescribed timeframe.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A loan disbursement notification was sent to the students in question; however, we can only document the loan disbursement notification was sent but are unable to document the date or content of the communication. Students identified with missing communications are from spring 2024. Our internal processes dictate that the notification would normally be sent on the date of disbursement. We will develop and implement a loan disbursement notification to loan recipient reconciliation process to effectively capture students with missing communications to ensure that both a record of the notification and the date are maintained.
FINDING 2024-003
Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. Additionally, 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 U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn (34 CFR section 668.173(b)).
Condition: The University did not appropriately return the amount of unearned funds within the required timeframe.
Cause: The University correctly determined the amount of Title IV aid earned for a student, but due to administrative oversight, erroneously processed the return of funds.
Effect or Potential Effect: Returns of Title IV funds were not made within the required timeframe.
Questioned Costs: None.
Context: For 1 of 6 students tested, the amount calculated as due for return was not appropriately returned.
Identification as a Repeat Finding: No similar finding identified in the prior year.
Recommendation: We recommend the University enhance its procedures over return of Title IV funds to ensure unearned portions of federal aid are appropriately returned to the U.S. Department of Education.
Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The University correctly determined the
amount of Title IV aid earned for a student within the required timeframes, but due to administrative oversight, omitted one of the required awards from the return update on the student account. A regular review of R2T4 calculations will be developed to ensure that the actual returns match the return calculations.